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Records Management Manual Changes -1997 Listed below are the sections which have changes in them as well as the sections which have been deleted or added. Due to the massive number of changes, please review these changes as well as the sections of the manual which apply to you. First Quarter: New Sections: Deleted Sections: Record Changes: 1161 1161 1161 1161 Change Change Change Change 1161 1161 1161 Change Change Change 1501A Change 1502A Add Case Histories, Non-U.S., U.S. Issued Case Histories, Non-U.S., Dropped Case Histories, U.S. Dropped Case Histories, U.S., Dropped With Live Offspring (CIP, etc.) Disclosures of Inventions - Inactive Patents, Originals, Non-U.S. (Dow) Patents, Originals, U.S. (Dow) not maintained Release of Proprietary Information to the Outside CHEC (Flammability/Reactive Expert System FlamES, RstatES) jeg 02/26/97 CONFTDFNTTAL. 00 006147 Second Quarter: New Sections: 999 Added Deleted Deleted Sections: 541 Delete 695 Delete 1201 Delete 1881 Delete Administration Chemicals and Plastics (Global) Planned Innovation Well Department Record Changes: 631 Delete 631 Change 631 Delete 631 Delete 631 Delete 631 Delete 631 Delete 631 Delete 631 Delete 941 941 941 941 1401 Delete Delete Delete Delete Delete 1401 1401 1401 1401 Delete Change Delete Delete jeg 02/26/97 Dateline, Master Dow Video File Footage Electronic Type Setting Disk Genigraphic File Graphic Arts Print Production Job Folders invoices, Art and Mechanical, etc. (Accounting Master) (Marketing Communication copy) Phone Logs Plan Books Reports on Outside Policy Making Organizations (including individual organizational files) O.P.I.C. Contracts and Regulations, All Terms Expired Renegotiation Reports Renegotiation Workpapers Thank you letters, and all other records Biographical Sketches and Photographs Other than Officers and Directors and Newsworthy Individuals, Former Employees Editorial Material, Master Copies (Sequence File Including Speeches) News Releases, Dow Today, Centerline, etc. Master (no backup) President's Letters Publications, Extra Copies, External/Internal CONF'idENT'IAL DO 006148 1401 1401 1401 1491 1721 Delete Delete Delete Add Add Scripts U.S. Public Issue Committee Minutes World Dow Press Analysis - Corporate Office Copy Department Statistics Keep-Out Notice Third Quarter: New Sections: Deleted Sections: Record Changes: 501 628 905 975 1401 1401 1401 1501A Add Add Delete Delete Add Add Add Change Benefits & Trust (HESP/SESP/Point of Service/Pension Recons Organization Charts Client Files (Scheduling Data) Signed Access Authorization Awards (President) Communications Advisory Panel (CAP) Contributions - Company Foundation Correspondence, General R&D jeg 02/26/97 OONFTDFNTTAt DO 006149 Fourth Quarter. New Sections: Deleted Sections: Record Chanaes: 628 628 721C 721C 721C 721C 731 731 731 861A Delete Delete Add Add Add Add Delete Add Add Change 861A 861A 901 9611 1001 1005 1091 1091 1761 Change Add Add Delete Delete Delete Delete Delete Change General Reference Material Reference Material, General Destroyed Cylinders Hydro-test Unit Pressure Gauge Calibration Hydro-test Facility 5-Year Requalification DOT Training Records Treaty Accounting Files Global Clearing Insurance Accounting Files (Treaty & Dow Programs) Title XXIII changed from Regulation Development Records to Requirements Records Environmental Incident Data Global Emissions Inventory (GEI) Shareholders of Record - Microfiche Reference Material Reference Files Reference Materials Health Services Reference Materials Reference Materials Reference Files changed to Tax Research Files jeg 02/26/97 OONFTDFNTIAl DO 006150 9008 Building December 8,1997 TO: Records Management Manual Holders If records are frozen and have expired retentions please call the appropriate contact person for Instructions pertaining to the storage of these records. Expired records are not to be retained in the owning department Please inform the appropriate people in your area of the documents which have been frozen. This freeze letter supersedes freeze letter dated December 2, 1996. Summary of the Tax Freezes Per the letters from Dorothy Hoffman dated November 1997, the following U.S. records are frozen" from normal destruction until further advised by the Corporate Tax Department. Section Number 501 751 905 907 913 Department Accounting Dow Credit Corporation Corporate Aviation Executive Dow Club/ CAC Financial Corporate Treasury Type of Record Years ______________________________________ Accounting Entries: Quarter End B&A Reports 1987 1987-1992 Customer Invoices 1987 IRS Computer Tapes (including Accounting Detail File and Source 1987 Dictionary) Financial Statements Miscellaneous Debits/Credits 1987 1987 Miscellaneous Invoices includes IDTs Property Schedules - Final Copies 1987 1987 Royalty Agreements (Expired) 1993 Subledger Cost Sheets 1987 Project Files (and all items listed under that title) 1992 -1993 Schedule Sheets - Dow Form #48010 1992 Reservations, Functions and Rooms Schedule 1992 Borrowings (other than Commercial Paper) (e.g.. Loans, MTN's) Debenture Issues (Public) Interest Rate Hedge Report Interest Rate Instruments Position Summaries/Accruals Interest Rate Instruments, such as Swaps, Swaptions, Options (except Exchange Traded) Investment Contracts Leases, Agreements, All Terms Expired Notes and Credit Agreements - Dow Copy Operational Systems Backup Tapes Project Financing (including leasing, investments, venture capital) Promissory Notes (including Intercompany/Subsidiary) Sinking Fund Purchase Confirmation Letters Tax Exempt Bond Records * 1987 -1993 also, if not already destroyed ** 1987 -1989 also, if not already destroyed *** 1987 -1992 also, if not already destroyed 1987-1990 1987-1990 1994-1996* 1987-1996 1987-1990 1990** 1993*** 1987-1993 1989-1990 1987-1993 1987-1993 1993 -1996*** 1987-1990 Restricted for Use Within Dow CONFTDFNTTAL DO 006151 Freeze Letter December 8,1997 Summary of the Tax Freezes Continued Section Number 1171 Department Payroll Type of Record Payroll Register; Check, Earnings, Tax, etc. Payroll Statistical Detail Tax Reports to Tax Department W-2 Statements and W-4 Forms Years 1987 f 1991 1987-1991 1987-1991 1987*1991 Summary of the Legal Freezes Per the letter from Pat Gruber dated November 1996, the following records are frozen1 from normal destruction until further advised. This freeze pertains to U.S. records unless otherwise indicated. D cument which is frozen - BRAZIL THEFT LOSS LITIGATION Brazil Theft Loss litigation - all documents created in the United States and Brazil generated from 1982-92 regarding sales transactions, business team meetings, internal controls and reporting within the various Dow/DowElanco locations. _______ ___________ ____________________________ ' C ntact Person Location Phone Number Greg Smith Midland (517) 636-8509 * Document which is frozen - EXXON CHEMICAL PATENTS INC. AND EXXON CORPORATION Complaint against Exxon Chemical Patents Inc. and Exxon Corporation filed October 25,1994. Docum nts subject to this freeze are those concerning any actual or potential use of any AFFINITY or ENGAGE polymer, or any composition/formulation containing such polymer, or any INSITE technology Polymer ("ITP") or any competitor polymer, commercial or experimental, in a wire and cable end-use application. This includes, for example, all test data and information in Dow's possession in the U.S. about the polymers per se and any composition/Tormulation containing such polymers which has been evaluated by Dow or its customer(s) as an insulating layer, a shield layer and/or as a jacket layer in wire and cable article. The data and information may be experimental or developmental or commercial and it may have been generated by Dow and/or its customers or even by Dow consultants. The data and information may be technical and /or business oriented and it may be in the public domain or it may be Dow Confidential. The business oriented information includes documents concerning Dow's polyethylenes for wire and cable which contain information on marketing, sales, customer, sales calls, competitors (particularly Exxon and Mitsui), product developments, pricing sheets/policies, costs, profits (actual or potential), financial projections, and the like. Primary sources of such data and information are likely to be within Dow's Polyolefins and Elastomers business and sales offices having responsibility for wire and cable. Particular emphasis should be applied to documents referring to any meetings or communications between Exxon and Dow or between Exxon and any potential or actual wire and cable customer (individually or collectively as an industry segment) concerning the use of any of Dow's polymers in the wire and cabl field or concerning Exxon's wire and cable patent (USP 5,246,783) or any Dow generated or customer generated Contact Person Duncan Stuart Location Midland Phone Number (517) 636-5750 D cument which is frozen - LIQUID CARBON DIOXIDE All documents relating to Dow's Purchase (i.e. purchase price, quantity, etc.) and use of Liquid Carbon Di xide in bulk in the United States but excluding pipeline or cylinder purchases for the period January 1,1968 to and including October 26,1992. No document collection is being made at this time but may be required in the future C ntact Person Jean Crites Location Louisiana Phone Number (504) 353-8166 Restricted for Use Within Dow 2 CONFTDFNTTAl, DO 006152 Freeze Letter Dec mber8,1997 Document which Is frozen - ASTRO-VALCOUR, INC. All documents relating to a complaint against Astro-Valcour, Inc., alleging infringement of Dow's U.S. Patent Nos. 5,424,016, 5,585,058, 4,640,933,4,663,361 and 4,694,027. The *016 and *058 patents are directed to extruded polyethylene foam containing a permeability modifier which has been perforated. The others are directed toward the use of isobutane to blow polyolefin foams. Dow's products which relate to these patents are its ETHAFOAM" sheet and plank products, and Its Strandfoam ** products. Documents subject to this freeze include: R&D reports and other documents relating to perforated or unperforated, extruded polyethylene foam in plank or sheet form, whether or not containing a permeation modifier. This includes records relating to processes for making the foam and using it as well as studies of the performance and characteristics of the foam. All documents relating to U.S. Patent Nos. 5,424,016, 5,585,058, 4,640,933, 4,663,361 and 4,694,027 and all U.S. and foreign patent applications relating to the subject matter of those patents. All correspondence, product and sales records, reports of call, manufacturing records and market reports, analyses and studies relating to perforated or perforated, extruded polyethylene foam sheet or plank products. This includes products of Dow, its competitors and its customers. Documents relating to extruded polyethylene foam products of AstroValcour, Inc. This would include any analyses or evaluations of Astro-Valcour products, or the markets, Contact Person Gary Cohn Location Midland Phone Number (517)636-2464 Document which Is frozen - BREAST IMPLANTS All documents referencing breast implants, or any component thereof, silicones; polyurethane, including polyurethane foam; toluene diisocyanate [*TDr]; and 'TDI' components including toluene diamine ["TDA"]; Scotfoam, Foamex. See attachment 1 to 'TDI" collection letter dated November 1,1993, and "Breast Implant Litigation" letter dated January 16,1995 and Attachment (continuing the 1994 freeze) for further explanation. These documents need to be retained for document requests in the Breast Implant litigation. Contact PersonLocationPhone Number Mary Terzino Midland (517)636-9246 Document which is frozen - OASIS PIPELINE FILES All collected records, currently located on the third floor Records Center at ABP in Freeport, arising from Contact Person Paula Matzke Location Freeport Phone Number 409-238-2688 Document which is frozen - HOUSTON LIGHTING & POWER RATE CASE FILES All twelve boxes of collected records, currently located on the third floor Records Center at ABP in Freeport, Contact Person Linda Fiegener Location Freeport Phone Number 409-238-5595 Document which Is frozen - CUSTOMER INVOICE RECORDS AND SALES RECORDS All customer invoice records and sales records currently being maintained on microfilm at the Global Records Center. Contact Person Location Phone Number Lynn Schefsky Midland 517-636-0523 Restrict d for Use Within Dow 3 confidential 00 006153 Freeze Letter Decembers, 1997 Document which is frozen - COMPLAINT FILES FOR THE DOW CHEMICAL V. SUMITOMO CHEMICAL COMPANY LTD. OF JAPAN AND SUMITOMO CHEMICAL AMERICA, INC. OF THE UNITED STATES AND SUMITOMO CHEMICAL COMPANY LTD., ALONG WITH INABATA AMERICA CORPORATION AGAINST THE DOW CHEMICAL COMPANY This freeze, originally issued October 18,1996, remains in effect. However, this freeze is modified to include documents related to a lawsuit filed subsequent to October 18,1996. On September 23,1996, Dow filed a complaint against Sumitomo Chemical Company LTD. of Japan and Sumitomo Chemical America, Inc. of the United States in Federal Court in Bay City, Michigan alleging infringement of Dow's U.S. Patent Nos. 4,499,255; 4,778,863; and 4,785,061. Sumitomo Chemical Company LTD., along with Inabata America Corporation and Summit Specialty Chemical Corporation, filed a complaint against The Dow Chemical Company on January 30, 1997, in the U.S. District Court of Delaware for a declaratory judgment of noninfringement and invalidity of Dow's Patent Nos. 4,499,255; 4,778,863; 4,785,061; 4,585,838; 5,028,686. The patents in suit relate to all "epoxy resins" and all processes for preparing "epoxy resins", such as cresol epoxy novolac resin, having low hydrolyzable chlorides. The term "epoxy resin* has been defined in the above lawsuits and will be used herein below to mean "any glycidyl derivative of any compound having at least one aromatic hydroxyl group or aromatic amine group per molecule that is reacted with any epihalohydrin wherein the reaction for preparing the epoxy resin utilizes an organic solvent". Documents subject to this freeze are: R&D reports and other documents relating to all epoxy resins, particularly, cresol epoxy novolac resins and particularly epoxy resins having low hydrolyzable chloride content. This includes records relating to processes for making the epoxy resins, particularly cresol epoxy novolac resins, and using the epoxy resins as well as studies of the performance and characteristics of the epoxy resins, particularly cresol epoxy novolac resins. Also, all documents relating to U.S. Patent Nos. 4,499,255; 4,778,863; 4,785,061; 4,585,838; 5,028,686; and all U.S. and foreign patent applications relating to the subject matter of U.S. Patent Nos. 4,499,255; 4,778,863; 4,785,061; 4,585,838; and 5,028, 686. Additionally, all correspondence relating to all epoxy resin products, particularly, cresol epoxy novolac resin products. This includes products of Dow, its competitors and its customers. All products and sales records relating to all epoxy resin products, particularly, cresol epoxy novolac resin products. This includes products of Dow, its competitors and its customers. All Reports of Call relating to all epoxy resin products, particularly, cresol epoxy novolac resin products. All manufacturing records relating to all epoxy resin products, particularly, cresol epoxy novolac resin products. This includes, but is not limited to, any and all documents prepared during the process of getting capital authorized for equipment necessary to produce epoxy resin products, particularly, cresol epoxy novolac resin products, and any underlying economic evaluations. All marketing reports, analyses, studies, etc., done or prepared in connection with all epoxy resin products, particularly, cresol epoxy novolac resin products. This includes products of Dow, its competitors and its customers. All marketing reports, analyses, studies, etc., relating to all epoxy resin products, particularly, cresol epoxy novolac resin products which mention any product of Sumitomo. Any documents relating specifically to all epoxy resin products, particularly, cresol epoxy novolac resin products. This includes products of Dow, its competitors and its customers. Documents relating to all epoxy resin products, particularly, cresol epoxy novolac resin products of Sumitomo. This would include any analyses or evaluations of Sumitomo products, or the markets, customers of applications for those products. The term "document" means a writing of any kind (original and any non-identical copy [e.g., a draft of the document or a "b.c.c." version with or without notes to the b.c.c. recipients] or a version with draft-marginalia), picture, phonographic recordings, and every other media on which information is recorded (e.g., hard, floppy or laser disks). Thus, the term is very broad and includes, without limitation, letters, memoranda, laboratory notebooks, reports, overhead slides, tables of data, books, periodicals, flipcharts, day planners, patent disclosures and applications, patents, product brochures, sales presentations, reports of call, fax messages, drawings, working papers, computer printouts, computer disks, photographic recordings, and the like. C ntact Person Joe Prieto Location Midland Phone Number 517-636-9361 stricted for Use Within Dow 4 CONFIDENTIAL DO 006154 Freeze Letter December 8,1997 HL Document which is frozen - ASBESTOS-RELATED DOCUMENTS All asbestos-related documents created in the United States. Also, all documents generated by contractors in connection with asbestos abatement projects on Dow premises. This freeze letter is to advise that the suspension of the records retention policy ("freeze") on asbestos-related documents initiated on December 17, 1990 has been modified but remains in effect and binding on all employees of The Dow Chemical Company in the United States. For the purpose of this freeze letter, an "asbestos-related document" is to be construed in the broadest sense. A "document" includes any communication of any kind, including originals and all non-identical copies (whether different from the originals by reason of notations made on the copies or otherwise). Examples of documents include, but are not limited to. correspondence, memoranda, statistics, presentations, notes, letters, contracts, reports, studies, invoices, statements, receipts, inter-office and intra-office communications, printed matter, computer printouts, electronic communications and storage, other data compilations from which information can be obtained or translated, tapes, worksheets, day planners and logbooks. A document is "asbestos-related" if it refers to "asbestos* in any way including, but not limited to. its uses, its presence, its potential health effects or its safe handling. If the document has the word "asbestos" anywhere on it, it is an asbestos-related document. Also, types of asbestos Include amosite, anthophyllite, chrysotile and crocidolite. Due to the broad nature of the initial freeze and document collection effort, the Legal Department has identified certain document categories that are exempt from the freeze. Additionally, some categories of documents continue to be "frozen" but uncollected due to sheer volume and economics. Important: If your files contain any asbestos-related documents marked with the Legal Department document number in the margin ("ST" followed by a seven-digit number) or stamped "produced f rthe asbestos database," it means the Legal Department already has a copy and It is not necessary to retain y ur copy beyond the normal retention time set forth in the Records Management Manual. Because the asbestos premises litigation continues to grow, it is important for the originator of any future documents to furnish such documents to the Legal Department. Custodians of future documents may opt to produce them as part of the annual records retention review process or periodically throughout the year. Guidelines and instructions for handling future documents are enclosed. Documents should be sent to the contact identified in the attached guidelines. Please ensure that all documents generated in connection with asbestos abatement projects are forwarded to Legal. Contractors performing this work must provide Dow a copy of all documents they create. Also, all documents pertaining to Industrial Hygiene or Environmental Department monitoring and testing for asbestos must be forwarded to Legal. If you have any questions regarding this freeze letter or the guidelines, please call Linda Fiegener (409/ 238-5595) or the Legal Department contact for your division. Contact Person Pattie Behmlander Anniece Zeno Pat Gaudreau Linda Fiegener Location Pittsburg, CA Plaquemine, LA Michigan Div Texas Oper and all other Phone Number (510) 432-5524 (504) 353-8768 (517) 638-7834 (409) 238-5595 Restricted for'" ' Within Dow 5 r.ONFtOFNTTAL 00 006155 Freeze Letter December 8,1997 Document which is frozen - FILM TEC Documents relating to the Film Tec litigation including those that relate to U.S. Patent 4,277,344; U.S. Patent 3,744,642; U.S. Patent 4,872,984; FT-30 membrane or UOP TFCL membrane or Hydranautics CPA-2 membrane; or Film Tec activities in makinq, using or selling Film Tec. UOP or Hydranautics membranes. Contact Person Location Phone Number Steve Arnosky Midland (517)636-0571 D cument which is frozen - DOW LIABI LITY INSURANCE COVERAGE Dow Liability Insurance Coverage Litigation (global) A. All claims, litigation and insurance files which contain one or more documents relating to allegations of personal injury or damage to property for which any of the foil owing are alleged to be legally or contractually liable: The Dow Chemical Company, any of its past or preserit subsidiaries, or any joint venture of which any such company was a part. THIS DOCUMENT FREEZE DOES NOT APPLY TO CLAIMS, LITIGATION, OR INSURANCE FILES RELATING EXCLUSIVELY TO THE PR<DDUCT SARABOND. 6. All documents comprising or referring to any liability irisurance policy, including any documents that related to the extent of coverage provided under such policies , issued to any of the following: The Dow Chemical Company, any of its past or present subsidiaries, or any joint venture of which any such company was a part. It is anticipated that this document freeze will remain in effect at least through December 31,1998. You will be notified in writing when this document freeze is lifted, Records which expire while this freeze is in effect should be sent to Records Retention; they should not remain n the originating department. Contact Person Location Phone Number Greg Smith Midland (517) 636-8509 Contact Person Location Phone Number Bill Herr Midland (517) 638-2053 * Service Mark of The Dow Chemical Company ** Trademark of The Dow Chemical Company Section Department Number 501 Accounting Type of Record This freeze affects all U.S. and Canada records: Years Subledger (Quarterly) Accounting Entries: Qtr End - Journal Vouchers Transaction Recaps: Voucher Lists (Payments made by Accounts Payable) Invoices (Paid in Accounts Payable) Check Register - Accounts Payable Source Docgrgent?: Cash Banks - Cash Disbursements Customer Adjustments/Offsets Miscellaneous Debits/Credits Miscellaneous Invoices Includes IDTs Cancelled Checks (All) Subledger Cost Sheet: IRS Computer Tape Accounts Receivable Quarter End Accounts Receivable Control Reports JV Control Reports (receivables) US ComDuter TaDes Accounting Detail File FP9050.IRSDATA Accounts Payable Detail FP9500.IRSDATA Accounts Payable Vendor File FP9500.IRSVEND Capitalization Support - Additions Authorizations 1987 1987 1987 1987 1991 1992 1992 1987 1987 1994 1987 1QQ9 1009 1987 1987 1987 1987 1987 Restricted for Use Within d 6 CONFIDFNTTAI DO 006156 Freeze Lett r December 8,1997 Summary of the Legal Freezes C ntinued Section Number 628 Department Communications (631) Environmantat and Hsalth Ragtiakxy Affairs Environmantal (661 A; 661B) Technology Cantors (1781 & 1781A) 631 Communications Type of Record The following related to Dow's historic waste management practices, philosophy and technologies, including the use of off site waste management facilities: General Reference Material Guidelines, Policies, Procedures, Standards a Manuals ~ Policies a Literature, Publication and Promotional Brochures - Original and Copies The following related to Dow's historic waste management practices, philosophy and technologies, including the use of off site waste management facilities: Issue Management Files Literature, Publications and Promotional Brochures General Reference Material Guidelines, Policies, Procedures, Standards (see Section 628) Manuals -- Policies (see Section 628) Years Retain all superseded Items of this description 1991 1992 1991 to present Retain all superseded items of this description 861A Environmental and Health Regulatory Affairs Environmental XV. Internal Reoorts A. Issue Management Team Minutes B. issue Management Team Policy Statements The followina tvoes of documents related to the Dalton. GA facility: VIIB. U.S. Area Environmental ComDliance Audits or Environmental Assessments/Consolidated Audits 1. Draft Audit Report 2. Final Audit Report 3. Corrective Action Plan(s) 4. Audit Working Papers (includes pre-audit questionnaire) 5. Status Reports 6. Follow-up Audit Report VIII. Enforcement Actions bv Government Aaencies (EPA. OSHA. FDA. ETC.) [only those action materials related to groundwater) A. Retain contents relating to enforcement action until case is closed B. Closed - Resolved/settled (except dispositive documents) C. Closed - Unresolved (except dispositive documents) D. Dispositive documents (i.e. consent decree, final judgment, settlement agreement) XIII. Groundwater Records fall items listed in manual1 1992 1994 Superseded Retain all superseded items of this d scription Retain all superseded Kerns of this description Retain all General Reference Material Guidelines, Policies, Procedures, Standards (see Section 628) Manuals - Policies (see Section 628) Retain all superseded Hems of this description Restricted for Use Within Dow 7 CONFTDFNTT At DO oo&i- Freeze L tt r December 8,1997 Summary of the Legal Freezes C ntinu d Section Number 861B Department Environmental and Health Regulatory Affairs Health Sciences Type of Record Reports related to the chemicals listed in Attachment A. XI. TSCA Section 8(c) Reoort of Adverse Reaction File Report of Significant Adverse Reaction, Occupational recordable Report of Adverse Reaction, Other, recordable Reports from Computer Log Report of Adverse Reaction, Not Recordable Disposition Letter Review Committee Minutes XII. TSCA Section 8(c) Reoort of Adverse Reaction Loa Computer entries for filed reports, Employee Health Computer entries for filed reports, Other Computer entries for reports not filed Indexes Statistical Reports Review Committee Minutes General Reference Material Guidelines, Policies, Procedures, Standards (see Section 628) Manuals ~ Policies (see Section 628) 901 Executive Environmental, Health And Safety Committee Minutes 1001 Legal General Legal Fees Paid - Backup for Report to IRS On* and Off-site Disposal Records Claims and Litiaation - (ExceDt Sg^tjpnd) Claims, Settled (complete file except releases, etc.) Claims, Settled (releases, etc.) Claims, Unresolved Environmental Claims, Unresolved/lnactive for Five Years 1502 Health And T.I.M.E. reports related to the chemicals listed in Attachment A. Environmental Sciences Years 1967 1992 1997 1997 1997 1997 1967 1992 1996 1997 1997 1997 Retain all superseded Kerns of this description 1992 1992 1947 1990 forward 1967 forward 1988 forward 1972 forward Retain all Restricted for Use Within Dow 8 CONFIDENTIAL DO 006158 Freeze Letter December 8,1997 Summary of the Legal Freezes C ntinued Section Department Type of Record Number 1551 Risk Management, Corporate Claims or Suits (Except SarabondJ Closed Liability and Workers Compensation Closed Property: (excluding Cargo and Household Goods) Cargo and Non-U.S. Household Goods U.S. Household Goods Insurance Manual Insurance Policies (oriainah Liability and workers compensation and related correspondence Property (beyond expiration and all claims closed) Insurance Policy Listings (current and expired master coverage list) Loss Information Years 1967 1982 1989 1990 Superseded 1893 forward 1967 forward 1942 forward 1967 forward 1781 Technology Manuals and Bulletins related to the chemicals listed in Centers and Attachment A. Products Ins. Litiaation: Environmental Technology Center Manufacturing & Sales Specifications Material Safety Data Sheets 1994 Retain all superseded Raw Materials Specifications 1994 Product Sales Bulletins 1991 1781A Environmental Technology Cvntsr General Reference Material Guidelines, Policies, Procedures, Standards (see Section 628) Manuals -- Policies (see Section 628) Work Products Design, operating and procedural guidelines Technical Memos Technical Reports Dow Plant. Site and Project Information General design information (not pertaining to a specific plant or project) Operating manuals Retain all superseded Kerns of this description Retain all superseded Retain all superseded Formal Reviews. Site Visits. Audits and Investiaations Checklists/formats for environmental, technology and other reviews Technology review reports and follow-up Waste contractor evaluation/audit reports Restricted for Use Within Dow 9 CONFIDENTIAI Retain all superseded 1992 1994 DO 0061&9 Freeze Letter December 8,1997 Summary f the Legal Freezes C ntinued Section Number 1781A Cont'd Department Environmental Technology Center Type of Record Competitive and Comparative and Technology Information Literature surveys related to technology Dow Bulletins. Manuals and Misc. Information Manuals (Hazardous Chemicals, Industrial Hygiene, Product, Product Stewardship, Quality Assurance, Reactive Chemicals, Safety, Transportation, etc.) Material, product & packaging lists and specifications Manuals and Bulletins related to the chemicals listed in Attachment A. Products Ins. Litigation: Manufacturing & Sales Specifications (see Section 1781) Material Safety Data Sheets (see Section 1781) Raw Materials Specifications (see Section 1781) Product Sales Bulletins (see Section 1781) General Reference Material Guidelines, Policies, Procedures, Standards (see Section 628) Manuals ______ - Policies (see Section 628)__________________________ _ Y ars Retain all superseded Retain all superseded Retain all superseded 1994 R tain all superseded 1994 1991 Retain all superseded items of this description Larry Bowling, Secretary Dow Records Management Committee Records Management (517) 636-0478 Restricted for Use Within Dow 10 ^CONFIDENTIAL DO 006160 Freeze Letter December 8,1997 ATTACHMENT A TO 1998 LEGAL DEPARTMENT INSURANCE LITIGATION FREEZE LETTER ENVIRONMENTAL INSURANCE LITIGATION CHEMICAL LIST: 1,1,2-TCA 1,2-dichbroethane 1,1-dichioroethane 1,1,1-trichloroethane 1,1,1-trichbroethene 1,2-dbhbroethene 1,1-dichloroethene 1,2-dichloroethene (cis/trans) 1,2-dichlorobenzene 1,1,2,2-tetrachloroethane 1,4-dichlorobutane 1,4-dioxane 1,2-dichloroethylene 1,1-dichloroethylene (vinyl chloride) 1,3-dichlorobenzene 1,2-DCA 1,2,4-trichlorobenzene 1,2-dichloropropane 1,1,2-trichloroethane 1,4-dichlorobenzene 1,1-DCA 1 -chloro-2-bromopropane 1 -methylnaphthalene 2,4-dimethylphenol 2,3,7,8-TCDD 2,4,5-T 2,4-dichlorophenoxyacetic acid (2,4-D 2-(2,4,5-trbhlorophenoxypropionic acid) (2,4,5-TP) 2-butanone 2-methylnaphthalene 2-methylpheno! 4-bromofluorobenzene 4,4'*DDE 4,4'-DDD 4,4'-DDT 4-methylpheno! 4-nitrophenol acenaphthene acetone acrolein acrylonitrile aldrin alkanes alpha-methylstyrene alpha-BHC aluminum ammonium bifluoride ammonium bicarbonate anthracene antimony aqua ammonia arochlor-1221 arochlor-1242 arochlor-1254 aromatics aromatic hydrocarbons arsenic barium beno(a)pyrene benzaldehyde benzamate sludge benzene benzo(a)anthracene benzo(a)anthracene/chrysene benzo(a)pyrene benzo(b)fluoranthene benzo(g,h,l)perylene benzo(k)fluoranthene benzoic acid beryllium beta-BHC bibenz(a)anthracene bio(z-ethylhexyl) phthalate bis(2-chloroethyl)ether bis(2-chloroisopropyl)ether bis(2-ethylhexyl)phthalate bromochbromethane bromodichloromethane bromoform bromomethane butyibenzyiphthalate c-1,2-DCE cadmium cabium cabium chbrbe carbon disulfide carbon tetrachbride chbrdane chbrinated hydrocarbons chbrobenzene chbroethane chloroform chloromethan chlorophenols chromium chrysene citric acid cobalt copper cumene cyanide delta-BHC di-n-butyl phthalate di-n-octyl phthalate dibenzo(a,h)anthracene dibenzofuran dibromomethane dibromochloromethane dichlorod if luoromethane dichlorofiuoromethane dichloromethane dieldrin dimethyl phthalate dioxin Dowtherm eldrin endrin ethafoam ethylbenzene ethylene dibromide fluoranthene fluorene forma Idehyd gamma-BHC heptachlor hexachiorobenzene hexachlorobutadiene hexachloroethane hydrochloric acid indeno(1 ,2,3-cd)pyrene iron isophorone isopropanol lead magnesium maiathion manganese Restricted for Use Within Dow 11 r.ONFTDFNTTAl qO 0061kl Freeze Letter December 8,1997 ENVIRONMENTAL INSURANCE LITIGATION CHEMICAL LIST Continued: m rcury methane methoxychlor methyl cellulose methyl methacylate methyl ethyl ketone methyl methacylate methylene chloride molybdenum naphthalene nickel nitrobenzene PAHs parathion PCBs pentachlorophenol perchloroethyiene phenanthrene phenol phenoiformaldehyde polyethylene polystyrene potassium pyrene selenium semivolatile organics silver soda ash sodium sodium bromate styrene styrofoam sulfate sulfide sulfur TCB tetraCE tetrachloroethane tetrachloroethene tetrachtoroethylene thallium thiourea copper complexor thorium thurane toluene toxaphene trichloroethane trans-1,2-dichloroethyelne trichloroethene (TCE) trichloroethylene trichlorofluoromethane trichlorophenoxyacetic acid (2,4,5-T) vanadium vinylidene vinyl toluene xylene zinc Restricted fcr'Jse Within Dow 12 COMf >0 06 Freeze Letter December 8,1997 PRODUCTS INSURANCE LITIGATION CHEMICAL LIST: Amitrole Herbicide Benzene Butadiene 1.3-butadiene Carbon disulfide Carbon tetrachloride Chlorothene 1,1,1 -trichloroethane (TCA) 1,1,2-trichloroethane Dibromochloropropane (DBCP or fumazonel Diethylene ether (1,4-dioxane) Dowclene Dowicide TTM Dowanol EB Dowanol NV Ethylene dibromide (EDB) Epichlorohydrin Esteron Garion 4 Kuron Methyl bromide Methyl chloride Methylene chloride Methyl ethyl ketone (MEK) Pentachlorophenol Perchloroethylene (PCE) Phenoxyherbicides 2.4-D 2,4,5-T D/Siivex D Silvex Polyvinyl chloride Styrofoam Tordon Tordon 101 Tordon 101M Tordon 101R Tordon 155 Toluene Trichloroethylene (TCE) Triethylene glycol Trimesol TyrinCPE Vikane Vinyl chloride Xylene Non-Dow Products Named Banvel Dioxin Diazonon Nitrosamines R stricted for Uce With;- " v 13 OONFTDFNTTAl DO 006163