Document mbjRGgo6rbj1J12p46bdO8MkJ

exhibit L' DOCUMENTS REQUESTED T~]) All reading or correspondence files of Plant Manager or other present or former DOW employee which might reasonably be expected to contain documents relating to industrial hygiene or safety matters or co-operation or participation in any industry sponsored trade assoeietion such as the CMA, the API, etc, or any subcommittee or subcommittee of such trade associations concerned with the toxicology, epidemiology, or health and safety matters with regard to benzene, vinyl chloride, or any other potentially toxic substance, including, but not limited to those listed in "Exhibit I.* 2. All reading or correspondence files of'any industrial hygienist or medical director with responsibility for your facility in Plsquemine between 1960 and 1987. 3. Any document of any kind of nature which relates to industrial health and safety, toxicology, epidemiology, including but not limited to documents received from industry or trade associations or any other document which in any way concerns the potential for exposure to benzene, vinyl chloride, or ethylene dichloride to cause any adverse health effect in humans or animals. 4. Any index of files or documents archived or stored by DOW which might reasonably be anticipated to include references to documents relating to Industrial Health and Safety, Toxicology, Epidemiology, membership in trade associations or any other document which in any way concerns the potential for exposure to benzene, vinyl chloride, or ethylene dichloride to cause any adverse health effect in humans or animals. Q:\wp51\GingwWngHo*nr<M442 Dow 0196 DO 2442p(C0NF^NTfAL DOW OSHA INCIDENCE RATE ORUTOB>lNaa OratATOU - LOT IN LAST 11 MONTS CONTRACTOR OSHA RATE w/ovrnnrv-j.iMA* WAHTT SUTV - 1M LAST 11 MONTHS OSHA'S NONE SSaM3ISSiI 3itM 1994 1993 DOW WEEK OF 10/16-10/22 s Ma im aM maM 1993 1994 1993 CONTRACTOR WEEK OF 10/16-10/22 OSHA'S NONE DAYS SINCE LAST DAWO MANHOURS SINCE LAST DAWO- 102 1,112,133 DAYS SINCE LAST DAWO MANHOURS SINCE LAST DAWC - 22 193,542 LOUISIANA DIVISION SUNRISE MEETING 10/24/95 DIVISION SAFETY ENVIRONMENTAL REPORT OUTSIDE COMPLAINTS % CAPACITY PLANT OPERATIONS POWER & UTILITIES, HYDROCARBONS, GRAND BAYOU CHLORINE/ CAUSTIC, CHLORINATED HYDROCARBONS OXIDES & DERIVATIVES, CELLULOSE, LGTI VECTOR POLY A, B & C, CPE ENVIRONMENTAL OPERATIONS MAINTENANCE MANPOWER CHRIS MESSELT DOYLE HANEY GERRY DAIGRE ART BOURG JOHNNY MASEY TERRY LEIGH BILL BERNAT MIKE STICKLEN DOYLE HANEY STAN COLE DOW CONFIDENTIAL DO 144227 CONFIDENTIAL 5RAGENDA.XLS October 13,1995 ^Kj_l r ,99s The Dow Chomical Company P.O. Bo* 150 Plaquemine, Louisiana 70765-0150 Harry Freeman, Executive Director Louisiana Environmental Leadership Pollution Prevention Program Room 804, Engineering Building University of New Orleans New Orleans, Louisiana 70148-2212 Dear Mr. Freeman, On behalf of Dow's Louisiana\Division, I'd like to express our support for and intent to participate in the Louisiana Envuonmemal Leadership Pollution Prevention Program. While we have a number of projects and activities currently underway that should qualify for the Program, we would prefer uyaelay-our official application until the first quarter of 1996. Our Company has recently annobx^ced that in 1994, we met our goal to reduce SARA 313 emissions by 50% otfeyftar ahead oHchedule. We are now in the final stages of drafting our Corporate Environmental Goals for the year 2005, which will include topics such as wastcandemission Eduction, energy consumption, and public accountability. These be challenging anXsignificant public commitments and it is our desire to coordinate our participationfc^the Environmental Leadership Program with our Corporate Goals. W^regret any difficulties this delay may cause, but feel that the resulting improved aligniheot with our corporate initiatives will be beneficial to all parties. Sincerely, Doyle A. Haney Environmental Manager <L^\ V^-'VT v 1 - c, . -VLl fljA , aV lo^! ^ \ uo*' .,.l. ,$.r. i5 DO 144228 CONFIDENTIAL TO: Bill Bemat, B-6650 Sharon Cole, B-6601 Stan Cole, B-4109 Ken Diamond. B-1901 Ronnie Fitzgerald, B-8601 Dwight Fontaine, B-3301E Tony Grant, B-807 Nickie Grissom, B-4801 Tun Gunn, B-1701 J. J. Hiemenz, B-8010 Cathy Holmes, B-3302P Roger Hudson, B-2801 Bill Jackson, B-6801 Charles Jackson, B-1501 Kevin Johnson, B-5701 Gretchen LeBlanc, B-3601 Teny Leigh, B-1601 Johnny Masey, B-3801 Carl Mercer, B-5301 Steve Mims, Grand Bayou Curt Modtland, B-4350 Steve Parker, B-5501 Dick Speed, B-901 Mike Sticklen, B-807 Don Taylor, B-4605 Rick Thornhill, B-2601 Wayne Turner, B-4501 A really great performance in 1995! Thanks, Ken Hasenbeck jzs/10-2-95 00 144229 CONFIDENTIAL WEEKLY ENVIRONMENTAL REPORT TOTAL NUMMK Of AGENCY WPORTAOLOS CUMULATIVE LAST WEEK AGENCY REP. WATER SPILLSNONCOMP. 00 AIR PER EXCEED. 0 AGENCY TOTAL 0 YEAR TO DATE 13 4 0 23 AGENCY REPPRTA8LES LAST-WEEKMEEK_ENPjNO_*/2MO) MONO THIS Wt*X POTENTIALLY SERIOUS AND SERIOUS INCiPEffTS MONK LAST WEEK PSE1 SEI 00 43 bill i ill n.i iiillJJilli Ji VMM mm iiumimmi MONTHS [imsjnwgiePrTi'i wYstan.? a>sasagcrr) 0 144230 conftdfNTtal Edwin W. Edwards Governor State of Louisiana Department of Environmental^QiMtttty ' William A. Kucharski Secretary u fojSepTtembbeerr1188', sjjA 4)^ Mr. Ken Hasenbeck, General Manager Dow Chemical U.S.A. Post Office Box 1 SO Plaquemine, LA 70765-0150 Re: Annual Compliance Inspection Dear Mr. Hasenbeck: On August 14 & 15, 1995, Kristina Killen and Karen Blakemore of the Air Quality Division visited your facility for the purpose ofdetermining compliance with the LESHAP Regulations. They were assisted by Messrs. Bruce Alexius, David Mihalik, David Wesson, Bob Brady, and other plant personnel. According to the report no emission problems were noted at time of inspection. We appreciate the cooperation that we received in this matter. If we may be of assistance to you in your efforts to comply with our program requirements, please contact our Capital Regional Office at (504) 295-8910. Sincerely, SRM:KK:ccw c: Ben Potier Regional Program Coordinator o recycled paper 144231 C0NF^eNriAL OFFICE OF AIR QUALITY P.0 BOX 82135 BATON ROUGE. LOUISIANA 70884-2135 AN EQUAL OPPORTUNITY EMPLOYER WEEKLY ENVIRONMENTAL REPORT TOTAL NUMMR Of AGENCY REPONTAOLES CUMULATIVE HSM LAST WEEK AGENCY REP. WATER SPILLSNONCOMP. 00 AIR PER EXCEED. 0 AGENCY TOTAL 0 YEAR TO DATE 13 4 0 33 AGENCY REPORTABLES LAST WEEK WEEK ENDING 0/2S/M1 NONC THIS WEEK POTENTIALLY SERIOUS AND SERIOUS INCIDENTS NON* LAST WBX PSE1 SS 00 42 wmwaYweui iwww OOWOTOKttflUMCflOff* tMtTOtVMYTO n i: h.in.i 1ill HiTfillhigilellill Ji i HiimniiHiiuiiii! MONTHS lastlhOui WdbGRsaFOTCNTiM.LT JfKibui MSEIET I DO 14-4-232 confidentTM1- August 23,1995 Th Dow Chemical Company P.O. Box 150 Piaquemme, Louisiana 70765-0150 Ken Hasenbeck Bldg. 2306 cc: Greg Schultz Gretchen LeBlanc Rick Thornhill Rc: YOUR QUESTION ON ATTACHED IN I have examined the data related to environmental incidents and there has been a significant improvement in our performance. We have had a number of caustic leaks and our 3 Dow reportable caustic leaks have occurred in the past 2 months (See table). As you know we have gone through an intensive review of our piping systems and have developed a prioritized plan to work on them. The criteria we used is going to have us working on chlorine systems as a priority over causdc. This is still the right game plan and we arc going to stick to it The result may be slower improvement on other leaks than we might wish. We will achieve improvement in agency and Dow reportables, will reduce the risk of a more significant incident with external impact, will meet maintenance and capital spending goals and will continue improvement of asset utilization. There are several caustic lines that are in unacceptable condition that will be repaired/replaced between now and the end of the year. Production Manager mas 00 144233 c0NF IDETNITAL UPDATE ON LOUISIANA DIVISION'SCATHODIC PROTECTION PROGRAM ^ The Spill Prevention Task Force was formed to determine the steps necessary to prevent hazardous chemical spills within the division. One of the action items generated by the Task Force was to have Maintenance Technical Services assume ownership of the Division's existing Cathodic Protection Program. A focal point from Maintenance Technical Services was appointed to assess the Division's cathodic protection. Dan Dunn, Mark Bartel, and members of the Texas Division, surveyed the division, and recommended the installation of eight deep wells to enhance the Division's protection. Figure 1 illustrates the protection that existed at that time. Unprotected areas, that is areas greater than negative 700 millivolts, are shown in red. Marginal areas, areas between negative 700 millivolts and negative 850 millivolts, are shown in green. Upon completion of the survey, existing Division rectifiers were inspected and repaired as necessary. In addition to this, the eight new deep wells were installed and energized. Figure 2 shows the results of these efforts. A significant reduction in the unprotected and marginal areas has occurred over the past several months. The protection continues to improve as the ground becomes more polarized. Safety concerns were raised before the deep wells were energized. The concerns centered around the fact that a small amperage exists in piping that is cathodically protected. When this piping is unbolted and separated, the potential for spark generation exists. No incidents have been reported since the deep wells were energized. All division rectifiers are now being periodically monitored for effectiveness, and pipe to ground surveys are continuing to assess the division's protection. A cost estimate to provide total division protection has been estimated at $50,000. This will provide the necessary anodes and one additional deep well and will insure total division protection. This money has been approved through the LAD Utilities Group. The results speak for themselves, the MTS materials group has done an excellent job assessing and improving the division's cathodic protection. Manpower to support this program has not been increased, and the program's cost has been minimal. MTS Superintendent DO 144234 CONFIDENTIAL September 27, 1995 The Dow Chemical Company PO Box 150 Plaquemine, Louisiana 70765-0150 Bruce Alexius Ervin Antoine Bob Brady Christine Baldridge Mike Brown Wiley Fisackerly Hank Grace Denise Hale Lynne Hanrahan Billy Hood Dan Jones Michelle Kelley Dave Mihalik Mark Mitchell Marty Morrison Kenny Phillips Greg Schultz Paul Soileau Joe Thomas Geralyn Trabeaux David Wesson The recent air inspection by the Louisiana Department of Environmental Quality not only resulted in no deficiencies cited, but also resulted in praise given for unique programs that you put in place to assure compliance. This is a testament that putting safety and environmental first does not necessarily result in pounds second, but that commitment is there when conflicting pressures ensue. Thank you for your outstanding performance. Ken Hasenbeck Vice President General Manager Louisiana Division sb September 15, 1995 TIm Dow Ch*mlcl Company P.0. Box 150 Plaquemme, Louisiana 70765-0150 W. C. Bemat B-6650 S. G. Cole, B-4109 D. G. Fontaine, B-3301E C. R Holmes. B-3302P W. B. Horton, B-2509 T. E. Leigh, B-1601 J. W. Masey. B-3801 M. J. Sticklen, B-807 Attached is a summarized set of recommendations from the Reactive Chemicals Study Group. I have asked Terry Leigh to take the lead on getting these recommendations implemented and have asked him to co-chair the Reactive Chemicals Committee. Please help Terry get these changes implemented as soon as practical. Thanks, .en Hasenbeck Jzs Attachment DO 144236 CONFIDENTIAL REACTIVE CHEMICALS PROCESS IMPROVEMENT TEAM RECOMMENDATIONS AND ACTION ITEMS 1. DRST shall set a uniform and consistent policy for the reactive chemicals process. Name a manufacturing manager as Reactive Chemicals Committee co chair. (End of September, 1995). Adopt recommendations for Reactive Chemicals Committee team membership. (Bid of September, 1995). Adopt the New Superintendent Review process. (End of September, 1995). Change the focus of the periodic reactive chemicals audit-management systems' audit. (Bid of September, 1995). Maintenance and Inventory Management shall own the reactive chemicals' operating discipline for ensuring correct materials and equipment are ordered and installed. (End of September, 1995). 2. Production manager Reactive Chemicals Committee co-chair shall ensure that appropriate goals and KPI's are established for the Reactive Chemicals Committee. Production managers shall set consistent goals for their respective areas. (End of December, 1995). Managers shall ensure appropriate reinforcement is implemented throughout the chain of command. 3. Ken will get buy-in from technology centers involved with LAD operations to enhance the technology centers' role in the reactive chemicals process, as defined by the PIP behaviors. (End of December, 1995) 4. Reactive chemicals focus will be included in the roll-out to the Division so that the Division leadership group understands their respective roles in the process. (October2, 1995) KUHIkMI arntt DO 144237 CONFIDENTIAL gorima HaJ G. Ginn Theron G. Ladner Greater Baton Rouge Industrial Managers Association UNIVERSAL PLAZA, 5215 ESSEN LANE, SUITE SIX BATON ROUGE, LOUISIANA 70809 TELEPHONE: (504) 769-0596 FAX * (504) 769-0289 Chairman Executive Director FROM: HAL GINN, CHAIRMAN, GREATER BATON ROUGE INDUSTRIAL MANAGERS ASSOCIATION,. INC. (GBRIMA) RON ANDERSON, CHAIRMAN, LABOR STEERING COMMITTEE TO: PLANT SAFETY GROUP MEMBERS GREATER BATON ROUGE INDUSTRIAL MANAGERS ASSOCIATION, INC. (GBRIMA) MEMBERS We have been collecting OSHA type data and have made plans to develop these statistics for analysis. Dr. Helmut Schneider, Department of Quantitative Business Analysis, College of Business Administration has agreed to assist in establishing the computer program from which the data can be analyzed. It is anticipated that the first report will be completed mid June 1995. Please have the completed forms on both plant employees and contractor employees back in the Greater Baton Rouge Industrial Managers Association, Inc. (GBRIMA) office by October 15. 1995. 9/15/95 OSHA DATA DO 144238 CONFIDENTIAL From: To: CC: Subj: LACSDC: :STROXCLAIR 2-AUG-1995 @LEADERSHIP. DIS STROXCLAIR SITE SAFETY PERFORMANCE 14:12:10.34 Our overall site safety performance both Dow and contractor is truly outstanding in 1995. Through your personal involvement and use of the behavior-based safety process, you have truly changed the safety paradigm. Please give my thanks to all of your folks for an outstanding result year-to-date. As we look to the second half of 1995, we must keep our focus on b haviors and reinforcement of the desired safe behavior. There were 4 Dow OSHA injuries in July. This compares to 8 for the first 6 months of 1995. To make certain that this is not an upward trend, your help is requested. Please review your actions and plans to eliminate injuries and review progress with your leadership team to ensure that the outstanding performance we had earlier this year is sustainable. Let's really get focused in the second half of 1995 by setting a target of less than 2 Dow OSHAs and less than 2 contractor OSHAs per month for the next 2 months. With continued efforts from everyone, I know we can do it. Thanks again for all your leadership. Ken Hasenbeck DO 144239 CONFIDENTIAL TO: LACSDC::U134470 LACSDC::SGCOLE LACSDC::FONTAINE LACSDC::HOLMES LACSDC::U912532 LACSDC::MASEY LACSDC::STICKLEN {U134470} BERNAT, WILLIAM (WC), 504-353-8034 (U432871) COLE, STAN (SG), 504-353-6131 {U432375} FONTAINE, DWIGHT (DG), 504-353-8330 (U432287) HOLMES, CATHY (CR), 504-353-5854 {U912532} LEIGH, TERRY (TE), 504-353-8913 {U432948} MASEY, JOHNNY (JW), 504-353-1549 {U738537} STICKLEN, MIKE (MJ) , 504-353-8591 SUBJECT: SAFETY PERFORMANCE Our Dow safety performance was very poor in July--five Dow OSHA's and almost a sixth. Please relight the fires and the focus on Dow injury reduction, we still have a chance to meet our 1995 targets, but only if we turn it around now! Please lead the change! Ken jzs/8-8-95 DO 144240 CONFIDENTIAL Building 2306 July 20, 1995 The Dow Chemical Company P.O Box 150 Plaquemine. Louisiana 70765-0150 Sharon Cole, Vinyl 2, B-6601 Ken Diamond, CPE, B-1901 Ronnie Fitzgerald, Poly C, B-8601 Tony Grant, Poly A, B-807 Nlckle Grissom, LHC 2, B-4801 Hm Gunn, Solvents/EDC I, B-1701 J. J. Hiemenz, Environmental Operations, B-8010 Roger Hudson, Power & Utilities, B-2801 Bill Jackson, LHC 3, B-6801 Charles Jackson. Glycol I, B-1501 Kevin Johnson, LGTT, B-5701 Gretchen LeBlanc, CA 2/Caustic, B-3601 Carl Mercer, Glycol 2, B-5301 Steve Mims, GBO Curt Modtland, VectorSBC, B-4350 Steve Parker, Ethanolamlnes/Glycol Ethers, B-5501 Dick Speed, Poly B, B-901 Don Taylor, Methanes, B-4601 Rick Thornhill, Chlorine, B-2601 Wayne Turner, Cellulose, B-4501 cc: Bill Bemat, B-6650 Teny Leigh, B-1601 Johnny Masey, B-3801 Mike Sticklen, B-807 REACTIVE CHEMICAL INCIDENTS The attached data indicates our frequency of reactive chemical incidents Is on the increase. I am extremely concerned about this trend. Please review your reactive chemicals procedures and make sure your teams are sensitive to this most critical area. It is our responsibility to ensure that chemicals are handled in a safe manner. Kevin Johnson is looking at our overall reactive chemicals program for any changes that are needed for the long haul. My immediate concern is that we reverse the trend we are on QUICKLY! Thanks in advance for your help, Ken Hasenbeck jzs Attachment DO 144241 confidential LAD REACTIVE CHEMICALS INCIDENTS (CUMULATIVE) 1995 INCIDENTS JUNE THREE DOW OSHA RECORDABLES (CUMULATIVE) 7/17/95 DO 144242 CONFIDENTIAL 7/19/95 DO 144243 CONFIDENTIAL LOUISIANA DIVISION SAFETY A LOSS PREVENTION STATISTICS JUNE IMS DOW OSHA Msdical Traatmant Casas (Inddant Rata) OSHA Raatrictad Work Caaaa (Incbant Rata) Days Raatrictad OSHA Day Away Work Casas (Inddant Rata) Days Away Total OSHA Rscordablss (Inddant Rata) Manhours Month 0 1 i 1 4 2 Oil) 331,641 m. IMS 5 (050) 2 (020) 4 1 (0.10) 4 8 (0.78) 2,012,682 1M4 JEfiiil 18 (0-88) 10 (0.46) 88 10 (0.46) 74 38 (1.81) OSHA Msdieal Trsalmant Caaaa (Inddant Rata) OSHA Raatrictad Work Casas (Inddant Rata) OSHA Day Away Work Caaaa (Inddant Rata) Total OSHA Racordablaa (Inddant Rata) Manhours Site Total OSHA Rscordablss (inddant Rata) Manhqjjrs Dow Off TV Inh Cm /Incident ttetal Work Days Lost Dow Indnrtrial Inluria Dow PSA* 0 2 0 2 306.955 (1.00) 11 8 5 25 2,145540 (1.03) (0-84) (0 47) (2-33) 33 (1.75) 22 (1.17) 11 (058) 86 (350) 4 730506 (1.00) 33 4,158231 (1-58) 0 (0.00) 0 7 (038) 18 7 37 ? 27 106 (2.60) 37 (096) 110 101 57 HASENBECK BERNAT COLE FONTAINE HOLMES HORTON LEIGH LOPEZ MASEY STICKLEN UHLMANN Other TOTAL DOW 1934 1995YIQ No. ia No. Jit 0 0.00 0 0.00 9 2.82 3 1.80 3 1.40 1 1.00 0 0.00 0 0.00 5 1.92 2 1.44 3 1.51 0 0.00 4 1.34 1 0.70 0 0.00 0 0.00 4 1.30 0 0.00 9 3.18 1 0.89 0 0.00 0 0.00 2 2.53 39 1.81 8 0.79 Contractor 1994 1995YTQ No. La 0 0.00 No. 0 La 0.00 9 2.50 4 2.28 5 4.25 8 2.36 0 0.00 0 0.00 8 6.47 4 6.14 2 10.82 0 0.00 13 3.21 4 2.20 0 0.00 0 0.00 19 6.31 2 1.35 8 3.55 3 3.64 2 49.39 0 0.00 0 0.00 66 3.50 25 2.33 SITE 1994 laSSYTO No. La USL La 0 0.00 0 0.00 18 2.65 7 2.04 8 2.41 9 2.05 0 0.00 0 0.00 13 3.39 6 2.94 5 2.30 0 0.00 17 2.41 5 1.54 0 0.00 0 0.00 23 3.78 2 0.68 17 3.34 4 2.06 2 4.97 0 0.00 2 2.13 106 2.60 33 1.59 7/17/95 DO 144244 confien AL NORTH AMERICA PROCESS SAFETY PERFORMANCE KEY PERFORMANCE INDICATOR PROCESS SAFETY CODE INCIDENTS (Reportable to CMA) 1995 1st Qtr. 1995 2nd Qtr. 1995 3rd Qtr. 1995 4th Qtr. 1995 1st Qtr. 1995 2nd Qtr. 1995 3rd Qtr. 1995 4tb Qtr. KEY PERFORMANCE INDICATOR The key performance indicator will be the number of process safety incidents which occurred as measured by the Process Safety Code Measurement System criteria. 1. Fires or explosions in process areas which cause $25,000 or more property damage. OR 2. Chemical releases of more than the threshold quantity of an `extremely hazardous substance* (as defined by SARA Title III Section 302) or a release of 5,000 pounds of a flammable material. OR 3. Fire, explosion, or chemical release which caused one or more serious injuries (DAW) or fatalities to Dow or contractor employees or overnight hospitalization of non-employees. These incidents will be reported and tracked to measure our performance and identify opportunities for improvement. CMKingMi July 11.1993 95_2nd.doc DO 144245 CONFIDENTIAL ENVIRONMENTAL INCIDENTS NORTH AMERICA 7/13/95 NOTE; Look lor 7 In a raw Mow h moan OorAnbIgM DO 144246 CONFIDENTIAL From: TO: CC: Subj: LARNDC::BLACK "Lori Black, LA R&D, 8REPORT.DIS BLACK REACTIVE CHEMICALS REPORT - JUNE 1995 504-353-1803' 7-JUL-1995 10:* Gary Phillips: LOUISIANA DIVISION REACTIVE CHEMICALS REPORT - JUNE 1. There were three incidents in June (YTD Total = 2. Ten Reactive Chemical Reviews were held: DATE _-- ------PLAKT - PK031 5/9/95 6/5/95 jr f / \ V LHC 3 - Reaction of Cleaning Solution and Hydrocarbons ijl Waste Bullet Tank / Glycol 2 - Barge Sampling Incident 6/6/95 R&D - Emulsions 6/16/95 Poly C - Magnesium Alkyl Reaction in Waste Bullet Tank 6/20/95 Clorine - Brine Consolidation Project 6/20/95 Cellulose - Consolidated Audit 6/22/95 CPE - Premix/Packaging Upgrade Project 6/28/95 Poly A - Isopar C Recovery Project 6/28/95 6/29/95 CA II - Speed Increase for Chlorine Compression * CPE - Consolidated Audit RECtl,jui if*' TYPE RREEVVIIEEWW Incident / ICjS Incident R&D Incident Capital Authorization Consolidated Audit Capital Authorization Prestartup Process Change Consolidated Audit LAD REACTIVE CHEMICAL INCIDENTS REPORTED IN JUNE Barge Sampling Incident A sample from a barge containing ethylene glycol was mistakenly labeled as caustic. The sample was then sent to the Chlor-Alkali lab, instead of Glycol 2, for analysis. The lab technician attenpted to titrate the sample with nitric acid and realized there was a problem when the sample started to foam. There were no injuries or property damage. Magnesium Alkyl Reaction in Waste Bullet Tank at Poly C DO 144247 CONFIDENTIAL Residual BEM (Butyl ethyl magnesium) which had been flushed from D-301C with Isopar C was transferred to a waste bullet tank which was thought to be empty. The tank however, had an internal dip leg which prevented removal of all the liquid during the emptying step. The liquid heel December 1, 1995 Th Dow Chemical Company P.O. Box 150 Plaquemine, Louisiana 70765-0150 Arnold Allemang 2030 Dow Center Midland ORGANIZATIONAL RECOMMENDATIONS FOR LOUISIANA DIVISION Attached are my recommendations for the Louisiana Division organization with the objective of no more than four-six layers. The key concept is the creation of four Manufacturing/Service Excellence Teams aligned as much as possible to business and technology similar areas. To link the four areas together and to provide overall site coordination, a Site Leadership Team comprised of site activity leaders (safety, maintenance, etc.) and representatives (manufacturing superintendents) from the Manufacturing/Services Teams will be formed. We will use two existing business manufacturing leaders to act as coach for the Manufacturing/Service Excellence Teams. One major manager will assume the role of site re-engineering manager and site services coordinator. This role will manage our transition to self-directed work teams and help either coordinate or directly manage miscellaneous site services. In the attachments are diagrams that show our thinking on how key site service functions will be organized. I think this structure meets the spirit of what you asked for, will let the division continue to function well with me gone part of the time, and gives me 50+ direct reports that I will learn how to handle. This will be announced as Phase I the week of December 11. We will initially start off with three major manager coaches for the transition period until Mike Sticklen leaves the site with the Dupont/Dow JV and then go to two major manager coaches. While the site knows the intent is to remove the assistant superintendent and shift leaders (we have only two per plant today) from a direct administrative role, we will not do so until we have gotten the training in place on how to make this system work. Everything I have read on this topic says rushing in without training is a formula for failure. Our training and implementation plan should get us fully implemented by the end of 1996 with our JV plants (VectorSBC and Dupont/Dow) being the last. We would like to go ahead with the proposed changes in the Safety and Environmental organization now if possible, but we could wait if need be. For your review, input and consideration. Ken Hasenbeck jzs Attachments DO 144248 CONFIDENTIAL MAJOR MANAGER ROLE CHANGES Below are my recommendations for changes in major manager roles for the division: Use two of the business manufacturing leaders as coach for the Manufacturing/Service Excellence Teams. Bill Bemat--Oxides & Derivatives Business Manufacturing Coach Fill in for me when gone Terrv Leigh--Vinvl/EDC Business (If a high potential person becomes available, this could be the place to move them.) Cathv Holmes Manufacturing Coach Site Re-engineering Manager Site Services Coordinator Johnny Masev Mike Sticklen Available for re-denlovment Dupont/Dow J.V.--will use as coach until he leaves Stan Cpig Dwight Fontaine Maintenance Activity Leader Engineering Activity Leader KFH/12-1-95 DO 144249 CONFIDENTIAL UO 1 4 4 2 5 0 C O N F ID E N T IA L 0 DRST Membership * Detailed on Page 2 Louisiana Division Organizational Model Overview M.S.E.T. - Manufacturing/Service Excellence Team 0 Coach - Cull partial person From: To: CC: Subj : LARNDC:-.BLACK -Lori Black, LA R&D, REPORT.DIS BLACK REACTIVE CHEMICALS REPORT - JUNE 1995 504-353-1803" 7-JUL-1995 10-* Gary Phillips: LOUISIANA DIVISION REACTIVE CHEMICALS REPORT - JUNE 1995 1. There were three incidents in June (YTD Total = 8) 2. Ten Reactive Chemical Reviews were held: . DATE PLANT - PROJECT TYPE REVIEW 5/9/95 LHC 3 - Reaction of Cleaning Solution and Hydrocarbons iny Waste Bullet Tank Incident 6/5/95 Glycol 2 - Barge Sampling Incident Incident 6/6/95 Rtp^---Emois4^s R&D 6/16/95 Poly C - Magtfe&ranrAlkyl Reaction in Waste Bullet Tank Incident 6/20/95 lorine Brine Consol-idafion" Pto4ect_ Capital Authorization 6/20/95 Cellulose - Consolidated Audit Consolidated Audit 6/22/95 CPE - Premix/Packaging Upgrade Project Capital Authorization 6/28/95 Poly A - Isopar C Recovery Project Prestartup 6/28/95 CA II - Speed Increase for Chlorine Compression Process Change 6/29/95 ^CPE - Consolidated Audit Consolidated Audit LAD REACTIVE CHEMICAL INCIDENTS REPORTED IN JUNE DO 144251 Barge Sampling Incident > CONFIDENTIAL A sample from a barge containing ethylene glycol was mistakenly labeled as caustic. The sample was then sent to the Chlor-Alkali lab, instead of Glycol 2, for analysis. The lab technician attempted to titrate the sample with nitric acid and realized there was a problem when the sample started to foam. There were no injuries or property damage. Magnesium Alkyl Reaction in Waste Bullet Tank at Poly C Residual BEM (Butyl ethyl magnesium) which had been flushed from D-301C with Isopar C was transferred to a waste bullet tank which was thought to be empty. The tank however, had an internal dip leg which prevented removal of all th liquid during the emptying step. The liquid heel Edwin W. Edwards Governor RECTO EC 11 1995* State of Louisiana j Department of Environmental Quality Mr. Ken Hasenbeck General Manager The Dow Chemical Company Post Office Box 150 Plaquemine, LA 70765-0150 Dear Mr. Hasenbeck: On August 14, 15 & 17, 1995, Ms. Karen Blakemore and Kristina Killen of the Louisiana Air Quality Division visited your facility for the purpose of determining compliance with the Louisiana Air Quality Regulations. They were assisted by Messrs. Bruce Alexius, David Mahalik, David Wesson and Ms. Christine Baldridge. Ms. Blakemore's report indicates that no air emission problems were noted at the time of visit. We appreciate the cooperation that we received in this matter. If we may be of assistance to you in your efforts to comply with our program requirements, please contact Karen Blakemore of our Capital Regional Office at (504) 295-8910. SRM:KJB:ccw c: BenPotier Seruguai R. Marti Regional Program Coordinator DO 144252 CONFIDENTIAL w recycled oaoer OFFICE OF AIR QUALITY P O. 80X82135 BATON ROUGE, LOUISIANA 70884-2135 AN EQUAL OPPORTUNITY EMPLOYER THE CHLORINE I UTE, INC., 2001 L STREET, N.W., WASHINGTON, D.C. 20036-4919 202-775-2790 Fax 202-223-7225 TO: Ken Hasenbeck, Dow Chemical North Amerigu. Location Manager **Cl $Q Charles L Mears. Chairman Norman E. Thogersen. Vice Chairman Dr. Robert G. Smerko, President CC: Steve Harper, Official Correspondent FROM: DATE: Arthur E. Dungan December 5, 1995 Ti r SUBJECT: 1994 Chlor-Alkali Manufacturing Facilities Incidents Report Plant Rankings Separately you have been sent a copy of the 1994 Chlor-Alkali Manufacturing Facilities Incidents Report. For 1994, 48 manufacturing facilities operating in North America participated in the survey. 19 were Category 1 (less than 200,000 work hours per year) and 29 were Category 2 (200,000 or more work hours per year). The incident rate for total recordable cases (OSHA) showed a decline of 6% from 1993 results. Results were 8% better than 1992. The following data are presented: All Facilities OSHA Recordable Incident Rate Median OSHA Recordable Incident Rate Large Facilities (200,000 or More Work Hours) OSHA Recordable Incident Rate Median OSHA Recordable Incident Rate Small Facilities (Less Than 200,000 Work Hours) OSHA Recordable Incident Rate Median OSHA Recordable Incident Rate Your Facility's Performance (Plaquemine) i OSHA Recordable Incident Rate 1 Work Hours 1 Your Facility's Ranking Among All Chlor-Alkali Facilities1 1 Your Facility's Ranking Among Similar Sized Facilities2 3.46 2.93 2.89 2.72 6.97 5.66 I 2.88 | 973,766 | 24 | 18 1 Also attached is a form to update the Chlorine Institute's Location Manager Mailing List. In the event that you have replaced the location manager to which this letter is addressed, please return the attached form to my attention. 1 1 = lowest incident rate; 48 = highest incident rate n ^*4253 C0NFWENTIft 2 1 = lowest incident rate; 19 (Category 1) or 29 (Category 2) = highest incident rate Louisiana Division Site Services Coordination 00 144254 C O N F ID E N T IA L 12/1/95 2 3 12/1/95 DO 1 4 4 2 5 5 C O N F ID E N T IA L > r 12/1/95 4 DO 1 4 4 2 5 7 o n f id e t n t ia l 1 Functional Activity Leader & Functional Coach Concept 2 Maintenance 3 Oxides & Derivatives + Misc. 12/1/95 6 Functional Activity Leader & Functional Coach Concept Engineering (Reviewed with Mike Rio) 12/1/95 Plastics Chlor-Alkali & Derivatives 7 Dow U.S.A, The Dow Chemical Company PO Box ISO Plaquemine. Louisiana 70765-0150 FACSIMILE COVER SHEET TO: Oa^iSL Qjh Name if-'HUL'fC Company_ Phone NoFax No. 577-Jg-/#V RoutineRush Comments: FROM: Name Phone No&4'33~ C </?/ Fax No. Date -- Time '3S 3-<P/ ^ ^rxJ //Total Number of Pages 00 1A4260 CONFIDENTIAL YOU ARE NOTIFIED THAT THE INFORMATION CONTAINED IN THIS FACSIMILE TRANSMISSION IS COMMUNICATION INTENDED FOR THE USE OF THE INDIVIDUAL WHO IS NAMED ABOVE. IF YOU ARE NOT THE INTENDED RECIPIENT, OR AN EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERY TO THE INTENDED RECIPIENT, YOU ARE PROHIBITED FROM DISSEMINATING, DISTRIBUTING, OR COPYING THIS INFORMATION. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ADDRESS SHOWN ABOVE BY THE U.S. MAIL AT OUR EXPENSE. THANK YOU Revised 5/15/92 FORM NO. L357-103 DOW CODE NO. 3574724 EXTERNAL USE ONLY EPA PROPOSED RULE 40 CFR PART 68 Risk Management Programs for Chemical Accidental Release Prevention George King The Dow Chemical Company DATE:: hi TO: W. C. Bemat, B-6650 S. G. Cole, B-4109 D. G. Fontaine, B-3301E C. R. Holmes, B-3302P T. E. Leigh, B-1601 J. W. Masey, B-3801 M. J. Sticlden, B-807 FROM: K. F. Hasenbeck B-2306_________ 00 144261 confidential GMKIng/reh May 24,19951 95-110a.ppt EPA RMP Proposed Rule OUTLINE Time Table Overview of Proposal Primary Concerns to Dow Recommended Actions DO 144262 CONFIDENTIAL iGMKIng/reh May 24,199 95-11 Ob.ppt EPA RMP Proposed Rule TIME TABLE Proposed Rule Published in Federal Register 10/20/93 4 Public Hearings - Washington D.C. 11/93 -1/94 Written Comments Submitted Workshops Conducted 02/16/94 7/94-10/94 Supplemental Notice 03/13/95 Public Hearing 03/31/95 Written Comments Submitted Workshops Conducted 05/12/95 ??/??/95 Final Rule Published in Federal Register Register Within 1 Year 03/96 03/97 All Plans Submitted Within 3 Years 03/99 r DO 144263 CONFIDENTIAL GMKing/reh May 24,1995 95-110c.ppt EPA RMP Proposed Rule OVERVIEW * STATUTORY AUTHORITY: Clean Air Act Amendments 1990 Section 112(r) 1) Purpose: To prevent the accidental release of listed substances and to minimize the consequences if any such release occurs. 2) List of Substances with Threshold Quantities 3) Risk Management Program for Chemical. Accidental Release Prevention. DO 144264 CONFIDENTIAL GMKIng/reh May 24,1995 95-110d1.ppt EPA RMP Proposed Rule OVERVIEW List of Substances - Final January 15f 1994 128 Toxics and Flammables including these common chemicals: Chlorine Anhydrous Ammonia Methyl Chloride Ethylene Oxide Vinyl Chloride Methyl Isocyanate Hydrogen Cyanide Hydrogen Sulfide Toluene Diisocyanate Phosgene Bromine Anhydrous Hydrogen Chloride Hydrogen Fluoride Anhydrous Sulfur Dioxide SulfurTrioxide r7jb 144265 CONFIDENTIAL OMKing/reh May 24,1995 95-110d2-ppt EPA RMP Proposed Rule OVERVIEW * Requirements for Chemical Accident Prevention REGISTRATION HAZARD ASSESSMENT PREVENTION PROGRAM Management System Process Hazard Analysis Process Safety Information Standard Operating Procedures Training Maintenance Pre-Startup Review Management of Change Safety Audits Accident Investigation Emergency Response Program RISK MANAGEMENT PLAN RECORD KEEPING AUDITS DO 144266 CONFIDENTIAL QMKing/reh May 24,1995 95-110d3.ppt RISK MANAGEMENT PLANS CONTENTS Copy of Registration Form For each regulated substance: 1. Summary of the hazard assessment (including worst case) 2. Analysis of off-site consequences (including worst case) 3. Accident history data For the facility: 1. Description of major hazards 2. Description of consequences of failure to control hazard 3. Summary of all actions taken to address these hazards 4. How significant accidental releases are prevented or mitigated Above intended to provide overview of the prevention programs. D 144267C0NfidenTial GMKing/r h May 24,1995 95-IIOai.ppt RISK MANAGEMENT PLANS CONTENTS continued Summary of Emergency Response Plan 1. Procedures to inform authorities 2. Position of point of contact between the facility and public authorities 3. Dates of drills and exercises completed and the results 4. Description of coordination with the LEPC Description of the Management System developed to implement and coordinate 1. The hazard assessment program 2. Prevention program 3. Emergency Response Program 4. An organizational chart showing responsibility for risk management programs Certification that information in RMP is true, accurate, and complete DO 144268 GMKing/reh May 24.1995 95>110e2.ppt CONFIDENTIAL RISK MANAGEMENT PLANS Submitted to: 1. Implementing Agency 2. State Emergency Response Commission 3. Local Emergency Planning Committee Reviewed and Updated At least every 5 years and resubmitted. Updated when new regulated substance is introduced or major change to facility. Made available to the public DO 144269 CONFIDENTIAL GMKIng/reh May 24,1995 95-HOF.ppt DOWS EPA RISK MANAGEMENT PLAN WORK TEAM Management Sponsor Ken Hasenbeck Team Leader George King N.A. Process S&LP Members: ArtMundt David Gustafson Tom Gibson Toby Threet Duane Barns Susan Barrett Kevin Johnson Corporate Risk Assessment N.A. Environmental Quality Corporate Process S&LP Env. Law Regulatory Group N.A. Safety Env. Law Regulatory Group LGTI - Louisiana Division Mission: To identify the key issues effecting Dow and to take action to influence the proposed EPA Risk Management Plan Regulations. Strategy: To make the EPA Risk Management Plan requirements as much like the OSHA Process Safety Management requirements as possible. DO 144270 CONFIDENTIAL GMIOngfrati EPA RMP Proposed Rule DOW CONCERNS * Definition of Worst-Case Scenario (vessel failure) Hazard Assessment (look-up tables / modeling) Part of Risk Management Plan Communication to public More likely scenarios (CEI) * Definition of Significant Accidental Release Goes beyond statutory requirements Human effects not plants and animals * Risk Management Plans - Summaries * Prevention Program should be OSHA PSM oo 144271 CONFTDENTTAL GMKing/reh May 24,1995 95>110g1.ppt EPA RMP Proposed Rule DOW CONCERNS * Tiering of sources based on risk w Tier I - no off-site impact from worst case release m- Tier II - minimal impacts, generic RMPs w Tier III - full implementation * VPP Recognition * Accident Reporting - no new requirements * Public Participation through the LEPC * Technology Options Analysis (inherent safety) * Linkage to Part 70 Air Permits DO 144272 CONFIDENTIAL GMKing/rah May 24,1995 95-110g2.ppt EPA RMP Proposed Rule RECOMMENDED ACTION I* EPA RMP Work Team will: Work with CMA to eliminate OSHA / EPA duplication *** Pilot risk communication to the public Continue to monitor progress and communicate DO 144273 cnpidfnttal GMKing/reh May 24,1995 95-110h1.ppt EPA RMP Proposed Rule RECOMMENDED ACTION * Support the implementation of the Process Risk Management Guidelines in your plants and with new capital project team. Update - F&EI and CEI mr Perform Consequence analysis triggered by F&EI and/or CEI mr Perform HAZOP on high potential risk areas of plants * Communicate results of above to plant personnel and begin risk communication dialogue with employees. * Wait for final rule. DO 144274 confidential OMKing/reh 3,%'TM From: To: CC: Subj : LACSDC::STICKLEN 9KEN "MIKE STICKLEN-PLASTICS-LOUISIANA (504-353 8591)" Process safety workshop RECDJUN 051995 Ken, we are holding a process safety workshop for all technical folks and first-line supervisors on June 19. Our intent is to increase awareness and focus on Process Safety. I have asked each superintendent to lead an investigation for their work group on a case study of the Poly A decomp. Mike PLASTICS SAFETY PROCESSES CASE STUDY SCOPE: Objective is to improve the knowledge of the current Safety Management Processes to prevent future serious incidents PERCEPTIONS: 1) Currently the scope of many of the MOC's cover the immediate issue and do not adequately address unusual or unplanned events, e.g. infrequent shutdowns, emergencies, or maintenance. 2) MOC's do not adequately address operations outside of current defined process limits, failing to generate cautions or stops before a serious incident occurs. 3) Failure to recognize the possibility that changes which may result in incidents aren't being covered with the current safety systems. 4) Current knowledge and emphasis in reactive chemicals is not as good as it should be. Using the March 19 Poly A Train 5 Decomp as a Case Study to illustrate issues that are present in the Louisiana Division, the group should determine how the current Safety Management Systems address these perceptions and how they could be modified to prevent reoccurence. Tentative Agenda Monday June 19, 1995 12:30 -2:30 p.m. New Hope/Reliance - Conference Center A. Description of History, Incident and Events 20 min - Bob Armstrong B. Discussion of Safety Management Systems and how they could be used; MOC, Tech Center, Reactive Chem, Safety & Envir Sup't, LPP's, CHEG's 20 min - Mark Mitchell C. Divide into five sections, the group develops a plan to use the systems to prevent this type of incident 35 min - Pit Supts to facilitate D. Break 5 min E. Combined sections discuss recommendations and develop prioritized lists of strengths and changes needed in current systems 30 min - Supts to present DO 144275 CONFIDENTIAL F. Agreed Summary and Action Plans from 10 min - Mark Mitchell/ TO: DIVISION EXPANDED LEADERSHIP GROUP SUBJECT: SAFETY PERFORMANCE Our Dow employee safety performance has been great year-to-date. Many thanks for your very focused efforts and outstanding results! The next area we are going for is a dramatic improvement in contractor safety on a site basis. We are trying for zero contractor injuries in June. I am asking each of you to support the Maintenance Teams' efforts in changing our contractor safety performance on a sustained basis. Please help reinforce the process we have set up for contractor safety and let's give it an extra boost in June. Thanks for your help and remember--safety and environmental performance first, pounds second. Ken Hasenbeck jzs/6-2-95 DISTRIBUTION LIST: LACSDC::U134470 ! {U134470} BERNAT, WILLIAM (WC), 504-389-8034 LACSDC::CHEW ! {U431404} CHEW JR, WOODY (WW), 504-389-6129 LACSDC::HANEY ! {U434403} HANEY, DOYLE (DA), 504-353-6128 LACSDC::HARICH ! (U431888) HARICH, PHILIP (PL), 504-389-8574 LACSDC::HENRY ! (U074923} HENRY, JIM (JE), 504-389-1509 LACSDC::HIEMENZ ! {U551472} HIEMENZ, JAMES (JJ), 504-389-1582 LACSDC::CJACKSON ! {U432798} JACKSON, CHARLES (CE), 504-353-6634 LACSDC::KJOHNSON ! {U138576} JOHNSON, KEVIN (KL), 504-353-5701 LAENV1::KALISH ! {U795015} KALISH, BOB (RL), 504-389-1618 LACSDC::MERCER ! (U433166) MERCER, CARL (CD), 504-389-6157 LACSDC::MODTLAND ! (U449981} MODTLAND, CURT (CD), 504-389-8515 LACSDC::PARKER ! {U434199} PARKER, STEVE (SM), 504-389-8679 LACSDC::ROBERTSON ! {U066134} ROBERTSON, ED (ED), 504-292-6591 LACSDC::SHIVELY ! {U060848} SHIVELY, JOHN (JW), 504-389-8045 LACSDC::SUIRE ! (U431342} SUIRE, ORAN (OJ), 504-353-8131 LACSDC::TURNER ! {U432981} TURNER, WAYNE (WA), 504-389-8491 LACSDC::BARRIOS ! {U430875} BARRIOS, CY (CA), 504-389-8654 LACSDC::BELLO ! {U431737} BELLO, GERALD (GA), 504-353-8111 LACSDC::BROOME ! {U434588} BROOME, JULIE (JA), 504-353-8653 LACSDC::BUCKLES ! {U434485} BUCKLES, CAREY (CA), 504-389-1740 LACSDC::RICHARDSON ! {U434455} HILL, LEIGH (VR), 504-353-1583 LAGTV1::U434166 ! {U434166} LEOPOLD, MICHAEL (MD), 504-389-8497 LACSDC::SAMPSON ! {U434495} SAMPSON, JOHN (JM), 504-389-8848 LACSDC::SLATER ! {U088395} SLATER, CATHRINE (CE), 504-353-1520 LARNDC: .-TOWNSEND ! {U433767} TOWNSEND, GLENDA P (GP), 504-353-1594 LACSDC::SGCOLE ! LACSDC::JADAMS ! LACSDC::MILLS ! LACSDC::RMOORE ! LACSDC::WROBERTS LACSDC::RTOUCHET LACSDC: -.CHAMBERS LACSDC::LDANIEL ! LACSDC::MACK ! LACSDC::JLANDRY ! LACSDC: .-CSMITH ! LACSDC::USIE ! {U432871} COLE, STAN (SG), 504-353-6131 {U433764} ADAMS, JEFF (JT), 504-389-1517 (U433954) MILLS, RONALD (RK), 504-389-6042 (U432987} MOORE, ROBERT (RD), 504-389-8337 ! (U431349} ROBERTS JR, WOODY, JR. (WT), 504-389-8410 ! {U432225} TOUCHET, RONALD (RS), 504-389-1519 ! {U433134} CHAMBERS JR, ROBERT (RV), 504-353-6224 {U431711} DANIEL, LLOYD (LC), 504-353-8597 {U434065} MACK, DEBBIE (DJ), 504-353-6234 {U434183} LANDRY, JIM (JD), 504-353-8022 {U229932} SMITH, CARLTON (CL), 504-353-8565 {U433481} USIE, PAM (PL), 504-353-8049 00 144276 CONFIDENTIAL DOWMAIL::U430845 ! {U430845} DAIGRE, GERRY (GW), 504-389-1602 LACSDC::U431557 ! {U431557} BABIN, BABS (BB), 504-353-8232 LACSDC: :U239297 ! {U239297} BARONE JR, GUY (GS), 504-353-8236 LACSDC: :UQ85950 ! {U085950} CAMBRE, GARY (GJ), 504-353-8265 LACSDC: :FONTAINE LACSDC: :BEARD ! LACSDC: :BROOKINS LACSDC: :COX ! LACSDC: :DAQUIN ! LACSDC: :HENDRY ! LACSDC: :HOOVER ! LACSDC: :LAFITTE ! LACSDC: :MONROE ! LACSDC: :ROUX ! LACSDC: :MWOODS ! ! {U432375} FONTAINE, DWIGHT (DG), 504-389-8330 {U434163} BEARD, ROBIN (RN), 504-353-6582 ! {U434459} BROOKINS, TOM (TM), 504-353-6441 {U432410} COX, WAYNE (WE), 504-353-8137 {U434421} D'AQUIN, DANE (DT), 504-353-8289 (U432744) HENDRY, RON (RL), 504-353-1559 {U229584} HOOVER JR, BILL (WL), 504-353-2362 (U433162} LAFITTE, LARRY (LL), 504-353-8985 {U431030} MONROE, JOHN (JC), 504-353-8169 {U432280} ROUX, PAUL (PE), 504-389-8153 {U433490} WOODS, MIKE (ML), 504-353-8024 DOWMAIL ::U074699 ! {U074699} GRAY, JOHN (JA), 504-389-8226 LACSDC: :HOLMES ! LACSDC: :ABOURG ! LACSDC: :BULLMAN ! DOWMAIL : :U433787 LACSDC: :HOWARD ! DOWMAIL ::U431091 LACSDC: :MESSELT ! LACSDC: :SANDS ! LACSDC: :SERPAS ! LACSDC: :U431337 ! LACSDC: :BELVIN ! LACSDC: :BUTLER ! LACSDC: :CARVILLE LACSDC: :CAUSEY ! LACSDC: :HEASLIP ! DOWMAIL ::U431113 DOWMAIL ::U432787 LACSDC: :DJONES ! DOWMAIL :U430940 LACSDC: ALOTT ! DOWMAIL :U433273 {U432287} HOLMES, CATHY (CR), 504-353-5854 {U430821} BOURG, ART (AJ), 504-389-8719 {U432984} BULLMAN JR, ARNOLD (A), 504-389-6109 ! (U433787) FISCHER, TED (TW), 504-389-8656 (U431947} HOWARD, FLASH (THOMAS) (TC), 504-389-8965 ! {U431091} MARIONNEAUX, EUGENE (EN), 504-389-8074 {U433023} MESSELT, CHRIS (CD), 504-389-2491 {U433296} SANDS, TOM (CT), 504-389-8326 (U434419) SERPAS, STEWART (SL), 504-353-8487 (U431337} ALMOND, CHARLES (CE), 504-353-8392 {U432606} BELVIN, MARGARET (MC), 504-353-1808 (U241658} BUTLER, JOE (JM), 504-353-6509 ! (U432273} CARVILLE, DONNA (DB), 504-353-1824 (U432483} CAUSEY, HELEN (HL), 504-353-8044 {U431285} HEASLIP, JIM (JP), 504-353-8475 ! (U431113} HERBERT JR, BILL (CW), 504-353-8587 ! {U432787} HUSSER, RONNIE (RW), 504-353-1537 {U433818} JONES, DON (DS), 504-353-6097 ! {U430940} LATIMER, RICHARD (RO), 504-353-8317 {U431307} LOTT, AL (MA), 504-353-8384 ! {U433273} POSTON, PERRY (PL), 504-353-8310 LARNDC: HORTON ! {U431366} HORTON JR, BOYD (WB), 504-389-1605 LARNDC: AINSWORTH ! {U431087} AINSWORTH JR, OLIVER C (OC), 504-389-1620 LARNDC: BOWLINRL ! {U431368} BOWLIN, ROGER L (RL), 504-389-1608 LARNDC: GROSS ! {U432154} GROSS, JOHN W. (JW) , 504-389-1715 LARNDC: STEVENS ! {U137964} STEVENS, JOHN (JW), 504-389-1661 LARNDC: WEEKS ! {U431822} WEEKS, THOMAS C. (TC), 504-389-1638 LARNDC: WESTJM ! (U431854} WEST III, JOHN (JM), 504-389-1643 LARNDC: GREGORY ! (U076474} GREGORY,STEVE (SD), 504-353-1823 LARNDC: HOLBROOK ! {U433060} HOLBROOK, MICHAEL T (MT), 504-353-1839 LARNDC: PRIERDG ! {U433111} PRIER, DONALD (DG), 504-353-1663 LARNDC: POPE ! (U432656) POPE, BRIAN (BG), 504-353-1636 LARNDC: CORAM ! {U434126} CORAM, PAUL (PT), 504-353-6486 LARNDC:: TOTH ! {U077787} TOTH, CHERI (CA), 504-353-8288 LARNDC:: WEST ! (U434327} WEST, DAVID (DH), 504-353-1786 LARNDC:: HEBERTLA ! {U434641} HEBERT, LARRY (LA), 504-353-1849 LARNDC:: GRIGSBY ! {U088047} GRIGSBY, DEAN (HD), 504-353-1868 LACSDC:: U912532 LACSDC:: SCOLE LACSDC:: DDUPUY LACSDC:: GUNN LACSDC:: GLEBLANC {U912532} LEIGH, TERRY (TE), 504-353-8913 {U434352} COLE, SHARON (SR), 504-353-6132 {U434375} DUPUY, DAVID (DW), 504-353-6365 (U433073} GUNN, TIM (TM), 504-389-1514 ! {U434307} LEBLANC, GRETCHEN (GC), DO 144277 CONFTDENTTAi 504-353-1642 LACSDC: :MULLER ! {U431855} MULLER, JOE (JJ), 504-389-8165 LACSDC: :OUBRE ! {U132118} OUBRE, MAURICE (M), 504-389-8953 LACSDC: :DTAYLOR ! {U434501} TAYLOR, DON (DW), 504-353-5855 LACSDC: :U432991 ! {U432991} THORNHILL, RICK (RD) , 504-382-4555 LACSDC: :CONLEY ! {U434090} CONLEY III, LEN (LN), 504-389-8404 LACSDC: :HEINS ! {U086047} HEINS JR, MONTY (EM), 504-353-6375 LACSDC: :KUHLMEIER ! {U069866} KUHLMEIER, RAY (RJ), 504-353-8478 LACSDC: :MCMURRAY ! {U434483} MCMURRAY, VIC (VE), 504-389-6148 LACSDC: :MILES ! {U433957} MILES, BRUCE (BE), 504-389-8613 LACSDC: :MYER ! (U140837} MYER, EDIE (EJ), 504-353-6495 LACSDC: :TNORMAND ! {U434515) NORMAND, TOM (TM), 504-389-1652 LARNDC: :PEEBLES ! {U432195} PEEBLES, RODDEY (RL), 504-353-1766 LARNDC: :PITTMAN ! {U433718} PITTMAN, EDWARD F (EF), 504-389-1853 LACSDC: :SANDOW ! (U434343} SANDOW, ALLAN (AD), 504-353-8887 LACSDC: :SMITH ! {U434185} SMITH, STEVE (SA), 504-389-6242 LACSDC: :SCHULTZ ! {U434391} SCHULTZ, GREG (GK), 504-353-8403 LACSDC: :WHITE ! {U434499} WHITE, SCOTT (WS), 504-389-6041 DOWMAIL ::U431842 ! {U431842} LOPEZ, RON (RA), 504-353-8369 LACSDC: :MASEY ! {U432948} MASEY, JOHNNY (JW), 504-389-1549 LACSDC: :SALLEN ! {U065063} ALLEN, SAM (SH), 504-389-8790 LACSDC: :GRISSOM ! {U432258} GRISSOM, NICKIE (NL), 504-389-6588 LACSDC: :U431581 ! {U431581} HUDSON, ROGER (RD), 504-353-1506 LACSDC: :BJACKSON ! {U433200} JACKSON JR, BILL (WL), 504-389-1884 LACSDC: :MIMS ! {U434092} MIMS, STEVE (SH), 504-353-5795 LACSDC: :RUSHING ! {U434422} RUSHING, LARRY (LP), 504-336-5360 LACSDC: :COOPER ! {U434519} COOPER, TIM (WT), 504-389-1812 LARNDC: :KLAWITTER ! {U033137} KLAWITTER, CHUCK (CL), 504-353-6166 LACSDC: :LYLE ! {U434496} LYLE, DONALD (DR), 504-389-6472 LACSDC: :MARTIN ! {U434432} MARTIN, HAROLD B. (HB), 504-353-1546 LACSDC: :MILLIGAN ! {U434435} MILLIGAN, STEVE (WS), 504-389-8100 LACSDC: :RAWLINGS ! {U433994} RAWLINGS III, JOE (JE), 504-389-1708 LACSDC: :TJROZAS ! {U434428} ROZAS, TOMMY (TJ), 504-389-6418 LACSDC: rESUPPLE ! {U431211} SUPPLE JR, EDDIE (ET), 504-353-5722 LACSDC: KTAYLOR ! {U434328} TAYLOR, KEVIN (KD), 504-389-8696 LACSDC: U075196 ! {U075196} HANRAHAN, LYNNE (LA), 504-353-6089 LACSDC: WITTMANN ! {U431826} WITTMANN, RICK (RW), 504-353-6863 LACSDC: ZAGONE ! {U434460} ZAGONE, JEFF (JP), 504-353-1598 LACSDC: JRWATKINS ! {U434598} WATKINS, JAMES (JR), 504-353-6726 LACSDC: CENKUS ! {U434197} CENKUS, MARK (MA), 504-353-8151 LACSDC: SHARKEY ! {U432797} SHARKEY, WILLIAM (WT), 504-353-6127 LACSDC: STICKLEN ! {U738537} STICKLEN, MIKE (MJ), 504-353-8591 LACSDC: DIAMOND ! {U431816} DIAMOND, KEN (KD), 504-389-6023 LACSDC: FITZGERALD ! {U434168} FITZGERALD, RONNIE (RS), 504-353-6521 LACSDC: SPEED ! {U136431} SPEED, DICK (RB), 504-389-8503 LACSDC: U432834 ! {U432834} GRANT, TONY (TF), 504-389-8646 LARNDC:: AKERS ! {U433735} AKERS, JAMES (JB), 504-353-6259 LACSDC:: ARMSTRONG ! {U431834} ARMSTRONG, BOB (RD), 504-353-8560 LACSDC;: BRADLEY ! {U434054} BRADLEY, TOM (TC), 504-353-6004 LACSDC:: BUCHOLTZ ! {U434632} BUCHOLTZ, DAN (DR),504-389-6451 LACSDC:: CBCARPENTER ! {U431750} CARPENTER, CHARLES (CB), 504-353-6165 LARNDC:: MITCHELL ! {U432898} MITCHELL, MARK (MT), 504-353-1869 LACSDC:: U089714 ! {U089714} PETERS, MARK (ME), 504-353-4790 LACSDC: : TERHOEVE ! {U434510} TERHOEVE, ANA (AS),504-353-8744 LACSDC:: YOUNG ! (U434553} YOUNG, MIKE (MR), 504-353-8948 LACSDC:: U033191 ! {U033191} UHLMANN, LESTER (LJ), 504-389-8211 LACSDC:: BURTT ! {U432118} BURTT, JAN (JL), 504-389-8251 LACSDC:: MEYER ! (U434622} MEYER, DOUGLAS (DP), 504-353-6767 LACSDC::U134594 ! {U134594} HASENBECK, KEN (KF), 504-353-6471 OO 144278 confidENTT*l SAFE BEHAVIORS FOR SUMMER HEAT HAZARDS PHYSICAL PROBLEMS - Slippery hands - Fogged monogoggles - Sweat in eyes SAFE BEHAVIORS EXAMPLES: Carry spare gloves Carry clean rag to dry ye protection BEHAVIORAL PROBLEMS - impatience - Hurrying - Shortcuts - Inattention EXAMPLES: Plan work Set appropriate work pac MEDICAL PROBLEMS - Heat cramps - Heat exhaustion - Heatstroke EXAMPLES: Take breaks Drink fluids 00144279 CONFIDENTIAL Respond to warning signs Limit time in slicker/ acid suits SAFETY & ENVIRONMENTAL PERFORMANCE FIRST - POUNDS SECOND >-j f/>-// i / / SAFE BEHAVIORS FORSUMMER - To: Dow and Contract Supervision CONCERN: Rash of injuries last two weeks Very hot weather earlier than usual * One case of Heat Exhaustion ACTION REQUESTED: *- Lead a IS minute tailgate meeting with your work group on Tuesday, May 23. & Discuss the heat hazards listed on reverse side and engage your work group in identifying safe behaviors to address these hazards D0144280 CONFIDENTIAL SAFETY & ENVIRONMENTAL PERFORMANCE FIRST- POUNDS SECOND 5/95 A^b CHEMICAL MANUFACTURERS ASSOCIATION Member Finn Incidence Rales per 200,000 Exposure Hours Year to Date through 12/31/94 Group Sire 3: More than 20,000,000 Exposure Hours per year Company Total Recordable Casa Rata DuPont Company 1994 0.95 1993 0.71 Merck & Co., Inc. 1.26 1.08 Occidental Chemical 1.55 2.02 Monsanto 1.67 1.62 Air Products & 1.72 1.85 Hoechst Celanese Corp. 1.95 2.57 Miles, Inc. 2.35 2.48 Dow Chemical Co. 2.42 2.49 BASF Corporation 2.54 2.52 Amoco Chemical Corp. 2.95 4.44 Eastman Chemical 4.22 5.21 Eli Lilly and Company 5.49 7.28 Union Carbide Corp. Group averages 6.81 C2.31 5.57 2^22} Number of companies reporting, 1994: 13 Number of companies reporting, 1993: 12 Deaths a Total Lost Workday Caaa Rata 1994 1993 0.39 0.25 Daatha a Total boat Workday Caasa Away from Work Rata 1994 1993 0.06 0.05 Total Hxpoaurs Hour a In thouaanda 1994 1993 119383. 128596. 0.43 0.47 0.28 0.28 42537. 41629. 0.71 1.10 0.31 0.44 25639. 27418. 0.54 0.57 0.36 0.42 32041. 33621. 0.82 0.67 0.21 0.19 22341. 22836. 0.96 1.28 0.35 0.56 44277. 46259. 1.16 1.30 0.81 0.97 44928. 47079. 1.09 0.99 0.49 0.40 42946. 45869. 1.07 1.27 0.52 0.58 30426. 33515. 1.53 2.34 0.19 0.43 26221. 29186. 1.84 1.88 0.25 0.11 30598. 31570. 2.95 4.54 0.87 0.49 27694. 6954. 3.61 2.71 1.11 0,75 22114. 22950. 1.08 0.99 0.38 0.37 DATE: indicate* no prior year data submitted TO: W. C. Bemat, B-6650 S. G. Col , B-4109 D. G. Fontaine, B-3301E C. R. Holmes, B-3302P T. E. Leigh, B-1601 J. W. Masey, B-3801 M. J. Sticklen, B-807 C*D./hsms*4Tf 3SCLt*J 03/02/95 Page FROM: K. F. Hasenbeck _____ B-2306 DO 1 4 4 2 8 1 C O N F ID E N T IA L RECU MAY 081995 2020 BUILDING May 2,1995 Th Dow Chomieal Company Midland, Michigan 48674 RESTRICTED FOR USE WITHIN DOW AND DOW SUBSIDIARIES DATE: A. A. Allemang, Mfg, Horgen J. G. Barksdale, Plastics &. Nitro Prod, Freeport / APB T. J. Block, Continental Operations, DOC D. B. Cattran, Mgmt, Fort Saskatchewan/201A R M. Croyle, Dow Environmental, 2040 K, R Davis, N.A. Operations, 2020 G. S. Dickson, N.A. Operations - Safety, 2020 K. F. Hasenbeck, Div Admin, Plaquemine/2306 TO: W. C. Bemat, B-6650 S. G. Cole, B-4109 D. G. Fontain .B-3301E C. R. Holmes, B-3302P T. E. Leigh, B-1601 J. W. Masey, B-3801 M. J. Stickler?, B-807 J. B. Martin, Corp Env, 2030 E. L. Rainwater, Oper Admin, Freeport/APB E. V. Reed, N.A. Operations - H.R, 2020 FROM: K. F. Hasenbeck B-2306_________ J. M. Rio, E&CS Admin, Houston Dow Center J. T. Smolarek, Management, Sarnia/21 G. R Veurink, Asset Utilization Resources, Freeport/APB J. A. Weymouth, Div Admin, 47/MI L. E. Wretlind, Chem/Hydrocarbons/Energy, Freeport/B-l 01 L. F. Wright, Corp Mfg & Eng, 2030 Attached are the "Safe Behaviors" for each level of supervision in Louisiana Division. It is an excellent approach to clearly defining the actions required of each supervisor to make a significant impact on safety. This is one of the approaches that Louisiana Division has used to improve safety performance. I liked the idea so well that I have written up "Safe Behaviors" for my own action (copy attached). I intend to work hard on these actions, and you should hold me accountable if I'm not giving them the proper priority. Bob Gallant ' N.A. Operations Attachments DO 144282 confidential SAFE BEHAVIORS FOR VICE PRESIDENT, NORTH AMERICA OPERATIONS Discuss/get feedback on safety on every site/plant visit. Include safety in all "State of the Business" speeches, satellite broadcasts, etc. Routinely call site managers to discuss current safety performance and activities. Set safety expectations, communicate progress, and aggressively push actions to achieve targets. Report on safety highlights at each North America Operating Board meeting. Send personal congratulations to sites/plants that achieve outstanding safety performance. Reinforce "Safe Behaviors" of direct reports; use negative feedback to address unsafe behaviors. Encourage Business Vice Presidents to include safety in their communications with sites/businesses. Regularly review tabulation of safety performance by Operations Leader, Site Process and/or Manufacturing Leader, Business and Technology. RWG 4/10/95 DO 144283 confidential .DOU ENVIRO. SERVICES TEL:504-353-8001 Feb 16'95 9:08 No.004 P.03/08 "SAFE BEHAVIORS" FOR GENERAL MANAGER Make it a point to discuss/get feedback on safety on every plant/department visit Reinforce "Safe Behaviors" of direct reports; use negative feedback to address unsafe behaviors. Ensure safety measures are routinely reviewed by DRST. Have Manager review any OSHA/serious incident in their area at Sunrise. Ensure that any OSHA/serious incident is communicated within one working day. Ensure safety is part of every agenda for high level visitors. Include safety in all Division "State of the Business" reports. Recognize site safety achievements/highlights. Set safety expectations and ensure progress. Participate in some safety audits. Begin/end meetings with a saf ty m ssag . SAFEBHVZPPT: 11/30/94 DO 144284 CONFIDENTIAL BOW ENVIRO. SERVICES TEL:504-353-8001 Feb 16'95 9:08 No .004 P.04/08 "SAFE BEHAVIORS" FOR MANAGERS Make observing for safety and intervening an integral part of every trip into the plant; it must take priority over checking for quality, productivity and/or cost Reinforce "Safe Behaviors1' of direct reports. Begin/end meetings with a safety message. Meet with Superintendents/Department Heads to formally review any OSHA/serious incidents. Devote time at staff meetings for each Superintendent to review progress/ideas on safety improvement Seek feedback from all levels in the organization on how safety improvement is being managed (Methods: written feedback, listening sessions, oneon-one's). Monitor key safety performance indicators. Attend some OSHA investigations. SAFEBHV2.RPT: 11/30/94 cconnLf1id4e4n28t5ial DOW ENUIRQ. SERVICES TEL:504-353-8001 Feb 16'9S 9 = 09 No.004 P .05/08 "SAFE BEHAVIORS'' FOR PLANT SUPERINTENDENTS Make observing for safety and intervening an integral part of every trip into the plant; it must take priority over checking for quality, productivity and/or cost Have periodic discussions with Production Supervisor about appropriate actions at all levels. Seek input from Operators on how their supervisor is managing improvement (Methods: written feedback, listening sessions, one-on-one's). Initiate initial and follow-up meetings with First Line Supervisors, Production Supervisor for consistent message in setting expectations and consequences. Meet with people exhibiting behavioral problems to ensure clear understanding of present/future consequences. Begin/end meeting with a safety message. When appropriate, insure communication of the root caus of Division OSHA's for learning value. Champion accountability - root cause in investigations normally points to behavior - acknowledge who is accountable in the investigation (accountability in public, discipline in private). Insure follow-up actions/consequences are based on root cause. Reinforce "Safe Behaviors" of direct reports. SAFEBHV2.PPT:11/30/94 DO 144286 CONFIDENTIAL .DOW ENVIRO. SERVICES TEL :504-353-8001 Feb 16'95 9:i0 No .004 P .Or'/Oi "SAFE BEHAVIORS" FOR PLANT STAFF Make observing for safety and intervening an integral part of every trip into the plant; it must take priority over checking for quality, productivity and/or cost. Discuss any observations with Production Supervisor. Discuss contractor observations with contractor foreman/supervisor, both positive and negative. Lead operator safety meetings, project reviews, etc. relative to potential safety problems on your projects. Personally set an excellent example -- follow S&LPs, use the required PPE, follow procedures, etc. Initiate use of MOC and ensure it Is rigorously applied. Make safety a part of job requests to operators to insure routine affirmation of the "Safety First, Pounds Second" message. SAFEBHV2.PPT: 11/30/94 DO 144287 CONFIDENTIAL POU Eh^IRO. SERVICES TEL:504-353-8001 Feb 16 ' 95 9 = 09 No.004 P.06/08 "SAFE BEHAVIORS" FOR PRODUCTION SUPERVISORS Make observing for safety and intervening an integral part of every trip into the plant; it must take priority over checking for quality, productivity and/or cost Reinforce "Safe Behaviors" of direct reports; use negative feedback to address unsafe behaviors. Have periodic, short one-on-one discussions with First Line Supervisors to clarity expectations and review supervisor's progress in spending time observing for safety, using positive and negative reinforcement etc. Follow up with First Line Supervisors on consequences planned as a result of root cause identification after an incident Talk with First Line Supervisors regarding C-9, Red Tag, Safe Work Permit compliance; discuss planned actions to improve. Participate with First Line Supervisors in talking with individuals about present/future consequences due to individual's inappropriate behavior. Train plant staff on safety observations and initiate follow up discussions on progress. Champion accountability - root cause in investigations normally points to behavior - acknowledge who is accountable in the investigation (accountability in public, discipline in private). SAFEBHV3.PPT: 11/3*3/94 00 144288 confidential DOU ENVIRQ. SERVICES TEL:504-353-8001 Feb 16'95 9:10 No.004 P.08/0 "SAFE BEHAVIORS" FOR FIRST LINE SUPERVISORS Make observing for safety and intervening an integral part of every trip into the plant; it must take priority over checking for quality, productivity and/or costs. Schedule time to observe direct reports performing work. Schedule time to observe contractors performing work. Routinely reinforce safe behaviors with positive feedback. When needed, use negative feedback to address unsafe behaviors. Train and remind operators to plan for safety before beginning a job; specifically, safe job procedure is understood, the right PPE is provid d, potential body position hazard considered, etc. Initiate tailgate meetings to discuss safety. Schedule short, occasional meetings with other department supervisors to share techniques, etc. Clearly demonstrate "Safety First, Pounds Second" by routinely making personal safe behaviors a priority. SAFESHV2.PPT: 11/30/94 0 144289 confidential From: To: CC: Subj : From: To: MARNOl::MARN01::MRGATE::*MRGATE::U085885" 25-APR-1995 09:24:02,26 U134594 rtJ JjJa- CONGRATULATIONS! ^ ws-?rr>k> NAME: U085885 <UO858850MRGATE@MARNO1> U1345940MRGATE m APR Distrib:S08VRNA_U085885_0001 Name: 95115CID1800 Comment: CONGRATULATIONS! <FF> 25-APR-1995 10:13 TO: U134594 --MADECD HASENBECK, KEN K F cc: U068213 --S08VRNA SUDERMAN, JUDITH J U700908 --S08VRNA SOSA, E J. / 2020 U069835 --SQ8VRNA DICKSON, GREG S. / From: MICHELLE RAJEWSKI, ISSUES MANAGEMENT, 2020 DOW CENTER, 6-9433 SUBJECT: CONGRATULATIONS! Ken, Congratulations to Louisiana Division for achieving 2 million manhours without a DAW. This is a very important achievement and continues the outstanding safety performance in 1995. I also hear that you have now gone over 1 month without a contractor OSHA. Louisiana Division is setting the standard for safety leadership in Dow North America. Thanks to all the people who are making it happen. Bob Gallant DO 144290 confidential >E 2020 BUILDING April 21,1995 RECD APR 2 6 1995 Tit* Dow Chamteal Company Midland, Michigan 48674 RESTRICTED FOR USE WITHIN DOW AND DOW SUBSIDIARIES DATE TO: J. G. Barksdale, Plastics & Nitro Prod, Freeport/APB TO: W. C. B mat, B-6650 S. G. Cote, B-4109 T. J. D. B. K. F. E. L. J. M. Block, Continental Operations, DOC Cattran, Mgmt, Fort Saskatchewan Hasenbeck, Div Admin, Plaquemine/2306 Rainwater, Oper Admin, Freeport/APB Rio, E&CS Admin, Houston Dow Center D. G. Fontaine, B-3301E C. R. Holmes, B-3302P T. E. Leigh. B-1601 J. W. Masey, B-3801 M. J. Sticklen, B-807 J. T. Smolarek, Management, Sarnia/21 G. R. Veurink, Asset Utilization Resources, Freeport/APB J. A. Weymouth, Div Admin, 47/MI FROM: K. F. Hasenbeck B-2306________ L. E. Wretlind, Chem/Hydrocarbons/Energy, Freeport/B-101 cc G. S. Dickson, N.A. Operations - Safety, 2020 Getter only) G. C. Phillips, Corp Safety/LP/Security, 2020 Getter only) Attached is the Reactive Chemicals Assessment done by a team led by Gary Phillips. There are some very key messages in this perspective on where we are and what we must do to improve. Please distribute this to your appropriate people and see that it receives the necessary priority. Our Reactive Chemical Incidents performance is not acceptable. Bob Gallant N.A. Operations Attachment DO 144291 CONFIDENTIAL 2020 Dow Center April 19, 1995 Th* Dow Ch*mici Company Midland, Michigan 48674 RESTRICTED FOR USE WITHIN DOW A. A. AUemang, Horgen R. W. Gallant, 2020 Dow Center cc: G. S. Dickson, 2020 Dow Center L. F. Wright, 2030 Dow Center M. R. Gambrell, Sao Paulo A. J. McKirdy, Hong Kong W. R. Knee, 2030 Dow Center M. N. Trask, 2030 Dow Center REACTIVE CHEMICALS ASSESSMENT The initial evaluation of the Reactive Chemicals status within the company has been completed per your request. A list of recommendations and issues have been developed that I want to communicate to you. These recommendations support the existing reactive chemicals process that has been successful for us. The recommendations as structured should not add work to an already busy organization. For the most part these recommendations address emphasis, focus and attention to discipline in areas that should already be part of the existing work process. Even though, overall, we may have plateaued in the area of Reactive Chemicals performance, we do not need to reengineer. There are a number of areas where significant improvements in efficiency and productivity can be implemented. Several have been identified and are included in the recommendations. Essentially, all of the recent reactive chemicals incidents have involved "known chemistry" known by the technical community but not necessarily known by the individuals involved in the actual work. This assessment has, thus, focused on the way we apply known technology and learning relative to reactive chemicals. The first part of the assessment involved Bill Knee and me reviewing our Technology Center reactive chemicals process and activities with ten of our "highest profile" technology centers. This was followed by informal visits with 23 plants in Europe and North America to review Operating Discipline and other practices involving reactive chemicals. This was an excellent format to discuss opportunities and heighten awareness with a number of plant operations people. In addition, six reactive chemicals consolidated audits and 11 new Superintendent reactive chemicals reviews were attended in order to help develop an overall evaluation and definition of the key drivers for reactive chemicals and process safety. This along with reviewing the root causes of some recent reactive chemicals incidents was the basis for the attached model for reactive chemicals and process safety. This model defines five key drivers or areas of emphasis for our plant operations. Deficiencies in any one of these five areas can result in a safety problem in the future. It may be noted that these key elements also drive efficient plant operation. I think this fits with your views relative to the relationship between plant safety performance to overall plant performance. DO 144292 CONFIDENTIAL Area Manufacturing VPs REACTIVE CHEMICALS ASSESSMENT Page 2 April 19, 1995 The other actionable issues are listed and attached with a suggestion of who should be responsible. I think most are self-explanatory; but I would like to spend some time in the future with you to clarify, answer questions and get your input The plan is to continue the assessment by visiting the other areas and sites, as well as work on the implementation of the attached recommendations. I look at part of my ongoing role as heightening awareness, defining opportunities and facilitating consistency with our reactive chemicals efforts. The plant visits seem to be a good way to accomplish this. If you think this effort needs a different emphasis, please let me know. Thanks for the opportunity to interact with the people and plants in your areas. Corporate Safety & Loss Prevention Attachments DO 144293 CONFIDENTIAL C O N F ID E N T IA L - Decisions Utilizing People with proper skills oO t* N) v0 A Belief it can Happen Realization of Magnitude of Potential Awareness of resources Corporate Memory Risk Asmt. Chemistry & Plant Capability Process History Uncompromizing Safety Attitude Clear Definition of Roles Planned Actions vs Reactive Utilize Resources Communication Application of Stds, Guldelin s & 0. D. Mgt. of Change Asset and People Protection Highest Priority New Superintendent Reactive Chem Reviews - Reviews should be done "by" the Supt. versus "for" the Supt. (RC Teams) - If Consolidated Audit is used for the New Supt. Compiianc the Review should be done by the Supt. (RC Teams) - Need to maintain the 90 day review compliance (RC Teams) - Encourage Manager Participation where Practical (RC Teams) - Maintenance Supt. should have Reactive Chem. Reviews and Training (RC Teams) - Research should Clarify and Communicate their Reactive Chem Audit and Review requirements (Research Safety and Mgt) o o oA ma >--I in CONF Operating Discipline - Improve Information Utilization Consider Collecting Root Cause of Incidents Mgr and All) (RC Reactive Chemicals Data Base Use_Knowledge of Existence, Speed, User Friendliness (RC Mgr) Dev General Graphical Training Materials (RC Mgr) Utilization of Risk Assessment Resource - Consider a Global Reactive Chemicals Standard (RC Mgr) - Training and Knowledge Is In Place with Plant Personnel Relative to Reactive Chemicals Recommend Training Reviews Include an Assessment of Comprehension (Plants, Management) Tech Centers should Periodically Recommunicate their Technology Picture or Video Incident Reminder Process (Tech Centers) Letter from Bill Knee Attached. DO 1 4 4 2 9 6 onftdetnttal Consider Dev. of Fundamental RC Chemistry Template for Technology (RC Teams and Tech Centers) Consider Technology Specific Reactive Chemicals Training for Technical People In a New Technology (Tech Centers and Plants) Tech Centers could Beniflt in Some Reactive Chemicals Technology Training 2030 DOW CENTER February 23,1995 TBCH CENTER MANAGERS TECH CENTER TECHNICAL MANAGERS Th* Oow CtMnaeal Company Miotana. Michigan 48674 RESTRICTED FOR USE WITHIN DOW AND DOW SUBSIDIARIES oc Greg Dickson, 2020 Dow Center John MdQtdy, Hong Kong Guy Phillips, 2020 Dow Center REACTIVE CHEMICALS As Gary Phillips and I have visited with several of the tech centers and their plants, the opportunity for improved communication of past reactive chemical incidents has surfaced several times. With the passage of time and the turnover of people, we can coilactiveiy "forget" some of our past learning experiences -- learning experiences for which we paid a high price. The tech cottas are looked upon as the repository of history for each of our technologies. They maintain the database of past safety, health, and environmental incidents that occurred both at Dow facilities and at the facilities of our customers, suppliers, and competitors. Periodically the tedi centers must re-comnumicate the learning value of these incidents if we ate to avoid repeating them. This is a part of our mission to Cooanunicate Technology. I believe that now, during 1995, is a good time for each tech center to re^ommunicate these teaming experioices to eadi production unit around the globe throughout their tedtnology. We have focused as a company on implemoning the Strategic Blueprint, re-engineering our work processes, and achieving the Produce Product Expectations. All these activities are critical to our survival and future. We must achieve competitive advantage. What we cannot afford to do is to lose site of the basics of running our operations safely and environmoitaUy responsibly. Through daily contact plant reviews, and periodic special communications the tech cotters cot contribute technology, operating discipline, training, and an historical perspective on the breakthrough improvements we need while diligently operating our facilities safely, soundly, and reliably. Best regards. P.S. Several people have suggested to Gary Phillips and me that pictures and videos of incidents are an effective medium of communication for reactive chemical incidents. You may want to consider building and maintaining your tech center reactive chemicals database to include these media. DO 144297 CONFIDENTIAL TO: LACSDC::U134470 LACSDC::U912532 LACSDC::MASEY LACSDC::STICKLEN ! {U134470} BERNAT, WILLIAM (WC), 504-353-8034 ! {U912532} LEIGH, TERRY (TE), 504-353-8913 ! {U432948} MASEY, JOHNNY (JW) , 504-353-1549 ! {U738537} STICKLEN, MIKE (MJ), 504-353-8591 CC: DOWMAIL;:U430432 {U430432} GALLANT, ROBERT (RW), 517-636-9639 SUBJECT: SAFETY PERFORMANCE Guys, I really appreciate the way all the units are running. Most, if not all, are at record performance levels. One area of concern I have in the area of safety is M.O.c. As we are making rapid changes in our processes, are we taking advantage of all the learning experiences of the past and the new tools we have today to make the technology changes we need to make safely? Would each of you step back and do a personal assessment of how your Teams are doing in the area of Safety, Reactive Chemicals, and Technology Reviews prior to making operating changes in your units. I don't need a report, just your personal involvement and comfort that we have top-notch practices that are used. Thanks, Ken jzs/4-25-95 DO 144298 confidential /deleft &C- /lw- Jxu/2^?- Maintenance Contractors Association Safety--Quality--Productivity P.O. Box 150, Plaquemine, LA. 70765-0150 RECU fviAS 1 (j 1335 March 6, 1995 Mr. Stan Cole Ma intenance/Construction Bld^. 4109 Mr. Cole: In support of Dow Chemical's 100% Compliance Safety Policy, each ember company of the MCA has authored individual progressive disciplinary action policies regarding the use of Personal Protective Equipment. These individual company policies are designed to ensure 100% compliance with Louisiana Division Personal Protective Equipment requirements. If any qu.esti.ons.arise"r0e0s. ulting from this letter, please Roliald C. Lee MCA President cc: Pam Usie MCA Files DO 144299 CONFIDENTIAL 2030 Building September 16, 1996 Th* Dow Owmteal Company Midand. Michigan 48674 DOW RESTRICTED, 7Ti To: Manufacturing & Engineering Global Leadership Team Business Manufacturing Directors/Leaders cc: Bill Stavropoulos, 2030 Dave Buzzelli, 2030 SEVERE INCIDENT INVESTIGATION PROGRAM Our safety performance is good and statistically on track to achieve our 2005 goals. However, our severity is high, as I addressed in my letter of September 10, 1996. The goal of no fatalities, that we have for each and every day, is not being achieved. The number and the nature of the fatalities that we experienced this year has demonstrated that our emphasis needs to be re evaluated, and we need to try a different approach to ensure that everyone working at a Dow site or on Dow business is truly focused on safety. To enhance our safety efforts, we will begin a Severe Incident Investigation program. The program will entail an investigation team that will, on short notice, go into a plant/site to investigate a current incident or recent incident that was either severe or had the potential to take a life. The investigation will be as rigorous as that done for a fatality. The investigation team will include a business manufacturing manager or site manager (team chairman), corporate safety manager, legal counsel, local technician, member of the most recent consolidated audit team, site safety manager and additional members based on the nature of the incident and to maximize safety learning. I believe we can accomplish this increased learning and emphasis from about four of these Severe Incident Investigations per year. This effort in no way replaces the current safety program that each business, site and department is currently implementing. As I said in my earlier letter, I firmly believe we will achieve a significant safety performance improvement from our behavior based safety programs. This initiative will impact few of you directly, however, it may give us insight into our safety performance that we will be able to leverage for all of us. It is expected that the plant/sites will address the team findings, while those opportunities that are found to have broader application will be addressed globally. We have reason to be proud of our past safety successes, however, our past is not a guarantee for future success. We must work hard at safety every day. It must be our number one priority. Manufacturing & Engineering Attachment DO 144300 CONFIDENTIAL