Document wr5N0OQ4zmMMeKd0m1aE2a1Z4

g[Ul )uu GUIDELINE #4 EMPLOYEE AND COMMUNITY SAFETY AND HEALTH Monsanto will provide a healthy and safe working environment for its employees and community neighbors and will monitor and evaluate employee health status, determine and monitor workplace factors affecting employee safety and health, maintain Monsanto workplace environmental guidelines set in accordance with Monsanto policy on human exposure limits, comply with governmental safety and health regulations, review major capital projects to protect the health of people at work and in the community and preserve company assets. PROGRAM 1. Continue to perform periodic on-site surveys of worldwide operations to evaluate total safety and industrial hygiene status. Utilize observations and recommendations to achieve and maintain regulatory and code compliance, attaining appropriate technological sophistication, reduce the probability of accidents of all types, furthering employee safety and health education, and generally assist the site in attaining year-to-year reductions in employee injuries and illnesses, as well as property losses. 2. Achieve and maintain compliance with governmental regulations and Monsanto guidelines as they relate to facility design, safe work practices, workplace exposures and community safety and health. 3. Monitor and evaluate employee health by periodic and special examination programs in U.S. plants - and in ex-U.S. locations where not precluded by local laws or customs. Utilize METU ("Medical Van") to perform health surveillance exams requiring special or innovative expertise or where local medical facilities are inadequate within the U.S. 4. Collect and enter workplace materials, worker exposure, work history and employee health data in the MEHI database which will be used to perform appropriate studies evaluating worker health to enhance worker protection. 5. Continue surveillance of workplaces to identify possible potential health risks, evaluate those risks based on current toxicological knowledge and initiate appropriate safeguards to protect the health of employees. 6. Establish guidelines for use in classifying and recording injuries and illnesses to monitor MONSANTO COMPANY company-wide performance and adherence to federal regulations regarding recordkeeping. Issue monthly summaries of appropriate statistics, and various publications designed to improve awareness and make available relevant technologies. 7. Provide corporate safety and industrial hygiene reviews on design, startup, and operational issues for major new installations and expansions. 8. Participate relative to safety and health through trade associations and other cooperative endeavors of the chemical and manufacturing industries. 9. Provide employee training, orientation and education in Safety and Industrial Hygiene. STATUS/OBSERVATIONS Program elements for this guideline are mostly in a sustaining mode as shown by the following observations: All Monsanto installations worldwide have S&PP surveys, generally annually, but no more than 24 months apart. Efforts to fully incorporate Fisher in the survey system are essentially complete. Those Monsanto installations having highly hazardous materials (HHMs), have had special audits and follow-up continues. All of the "Monsanto" plants worldwide except Fisher ROW have completed initial database surveys. All of these locations in the U.S. and Europe and 95% of the ROW plants in which Monsanto has controlling interest have also completed baseline monitoring for regulated substances, meet Monsanto workplace environmental standards, and are implementing DSW 117715 SECTION 4 Page 1 STLCOPCB4032252 EMPLOYEE AND COMMUNITY SAFETY AND HEALTH (continued) sustaining industrial hygiene programs. All other locations worldwide are currently being addressed in an effort to ensure that all locations in which Monsanto has controlling interest are consistent with Monsanto standards. There were nine OSHA inspections in 1985, about equal to the experience of 1984. Eighteen citations resulted from six of these inspections, eleven of which are still under legal contest; seven were received at Marshalltown for respirator policy and lead exposure from welding and paint spray operations while AN spills and labels were involved at other locations. Twenty inspections in 1986 resulted in 85 citations from only six of these inspections. Seventy-six are under legal contest while nine were accepted. Forty-two citings involve recordkeeping omissions that are being vigorously contested because of eighteen willful classifications. The addition of MARS to MEHI at the end of 1986, greatly improved the acceptance and usefulness of the database. Corporate, company, and plant staffs have continued to use the MEHI system to develop data for regulatory, legislative and litigation activities. Increased plant usage of MEHI/MARS is improving the quality and timeliness of data entry to the system. To assess consistent health surveillance, an updated Occupational Medicine Manual was completed and distributed to plant management, plant nurses and physicians. Approximately 100 major capital projects in 1985 had loss prevention and environmental control reviews. This identical approach continues with engineering as part of the operating units. Approximately 70 loss prevention reviews were held in 1986 in support of major capital projects, other special assessments included reviews of two potential acquisitions and three comprehensive risk studies. Monsanto continues to lead an industry group to develop Emergency Response Planning Guidelines for HHMs to help train plant management to make the proper decisions regarding Community Emergency Notification and Safety. Monsanto continues to support and participate in the CMA CAER program; more effort will be necessary to achieve compliance with Title HI Emergency Response. (Revised and Approved: Environmental, Safety & Health Committee April 28, 1987.) DSW 117716 SECTION 4 STLCOPCB4032253