Document wQLy1XbV3ggjMJ3EnkQam23

PLAINTIFF'S EXHIBIT BASIC REQUIREMENTS FOR AN INDUSTRIAL HYGIENE PROGRAM CONTENTS PAGE 1. Statement ........................................................................................... 1 2. Introduction ...................................................... 2 3. Basic Requirements ........................................................................... 3-6 CT O'* cn OCCUPATIONAL HEALTH POLICY The Dow Chemical Company The Dow Chemical Company will implement appropriate action to further protect the health of Dow employees and the public by continuing'to the health and environmental information related to its processes and products. As with safety, occupational health is the direct responsibility ofmanagement as well as a responsibility of each Dow employee. October 1S84 MS LT) cr> THE DOW CHEMICAL COMPANY INDUSTRIAL HYGIENE PROGRAM INTRODUCTION An effective Occupational Health program is the objective ofthe Dow "Occupa tional Health Policy" and "Dow and the Work Environment". Industrial Hygiene together with Occupational Medicine programs are important ele ments of the Occupational Health program. Dow's commitment to provide and maintain a healthy work environment is the foundation for basic requirements upon which all Area Operations can build their own Industrial Hygiene programs directed at their specific needs. Many of the requirements are based upon and referenced to existing Dow principles, guidelines and programs. Line management has the responsibility to maintain a healthy work environ ment. Industrial Hygiene functions are provided on a Corporate, Area and location basis to assist line management in maintaining that healthy work environment. BASIC REQUIREMENTS FOR AN INDUSTRIAL HYGIENE PROGRAM Each location shall establish an Industrial Hygiene Program for the detection, surveillance and control of potential health hazards which can potentially affect the health of its employees and that of the public. The program shall include the following specific elements and systems. 1. GENERAL a. A person shell be assigned to coordinate the program. b. Technical support will be provided to assess the health and environmen tal information related to intended uses of Dow products. c. The industrial hygiene function will actively participate in hazard com munication programs. d.A written description of the overall program including a means for implementation is expected to be present. e. The program status shall be reviewed annually by the location and periodically by Corporate Occupational Health personnel The industrial hygiene function will maintain ongoing communications with occupational medicine and other functions (e.g. Safety, Tbaricology, Epidemiology and Environmental Services) to assess the effectiveness of established programs. co CO o c~\ CO --1-- 2. IDENTIFICATION AND PRIORITIZATION OF NEEDS a. Operations, emphasizing R&D and Manufacturing, shall be analyzed to identify exposures to chemical, biological and physical agents with poten tial health significance in the workplace and to set priorities for training, monitoring, and control activities. b. A mechanism shall be established to review the industrial hygiene con siderations of the design, modification, divestiture and acquisition of facilities and processes. c. Support will be given in reviewing and ring the health considera tions resulting from the use and distribution of Dow products to customers and potential impact to the public. 3. EXPOSURE EVALUATION a. A written plan shall be established for conducting periodic reviews to evaluate potential sources ofexposures, the effectiveness ofcontrol meth ods and to set priorities for in-depth exposure monitoring. b. Industrial hygiene monitoring surveys be performed with sampling strategies designed to produce cost effective exposure data and estimates which are useful for correlation with medical surveillance data and for evaluating compliance with Dow exposure guidelines and government regulations. c. A system shall be established to ensure data quality. 4. EXPOSURE CONTROL a. A mechanism shall be established for selecting and applying appropriate corrective measures where monitoring results, new information or other observations indicate a need to reduce the potential for exposure during normal operations as well as emergencies. b. Engineering control shall be emphasized, but consideration must also be given to administrative and work practice controls and to the provision and use of personal protective equipment. 5. COMMUNICATION AND TRAINING a. Communication and training programs h11 be provided for employees potentially exposed to chemical, physical or biological agents. These programs shall include contractors as appropriate. b. Employees shall be informed ofthe following: the potential health effects of chemical, biological and physical agents; location of health and safety information sheets; methods to detect and control exposures; levels of exposures and employees' responsibilities to follow established safe work practices. U~) ZD O t 6. DATA MANAGEMENT a. Procedures shall be established for the timely documentation and com munication of findings from industrial hygiene surveys. b. Formal reports and/or data management systems shall be used to orga nize, store and retrieve industrial hygiene chemical inventories, ex posure data, work history data and training records. 7. REGULATORY COMPLIANCE Knowledge of applicable regulations shall be acquired. Programs shall be established and implemented to achieve compliance with government reg ulations.