No 2 Copy of Audit Rating Example

8/10/2019 No 2 Copy of Audit Rating Example

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05.01 Leadership Responsibility

05.02 Planning

05.03 Implementation and Operation05.04 Checking and Corrective Action

05.05 Management System Review

Common Management System


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0.0

1.0

2.0

3.0

4.0

5.0

06.01 Community Awareness andOutreach

06.02 Distribution and Logistics

06.03 EH&S Engineering Design andControl

06.04 Emergency Preparedness and

Response

06.05 Employee Health and Safety

06.06 Non Dow Services

06.07 Pollution Prevention

06.08 Process Safety

06.09 Product Stewardship

06.10 Security

6.0 Responsible Care


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Sample Size.

05.01 Leadership Responsibility 56%

A. General Requirements

1. Executive leadership shall establish, review, improve and deploy policies, companystrategies and direction and overall performance expectations.

NA

2. Executive leadership shall measure and review the overall companys performance. NA

3. Leadership shall ensure the companys policies, requirements, strategies, directions and

performance expectations are communicated and implemented.

NR

4. Leaders shall establish and communicate performance-based expectations to their

employees.

NR

5. Leaders shall deploy a comprehensive continuous improvement philosophy throughout the

organization, including all processes and support services.

5

6. Leaders shall conduct, with appropriate employee involvement, annual management system

reviews as described further in element 5.5 Management System Review.

NR

7. Leaders and their business or department representative shall ensure that: the ODMS is implemented and maintained per this standard,

the ODMS systems performance, including the management system review, are reported to

leadership for review.

NR

8. Business leaders shall set expectations and requirements for customer satisfaction/ loyalty

and market focus.

NA

B. Resource Requirements

1. Leaders may appoint a "representative" to manage the implementation of this standard as

well as serve as the Management System Review Team Leader as long as they ensure the

"representative" is qualified.

4

2. Leaders shall define and document the roles and responsibility, authority, and organizational

structure of personnel who manage, perform and verify work, particularly those who need the

organizational freedom and authority to: initiate actions to reduce costs, eliminate wastes and continuously improve the management

system,

initiate action to prevent product, service, process or system non-conformances,

identify and record product, process and system problems,

initiate, recommend or provide solutions,

verify implementation of solutions,

control processing and delivery of non-conforming material until the deficiency has been

corrected.

represent the customer in internal functions addressing QS-9000 requirements

5

3. Leaders shall be responsible for the identification of resource requirements; provision of

adequate resources, including trained personnel; and the assignment of roles needed to

support the management system, specifically performance of work and verification activities

including self-assessment and internal audits.

4

4. Leaders shall establish the boundaries of empowered teams, including specific expectations

and balance of consequences.

5

C. Automotive Requirements

1. Automotive leaders shall ensure organizational interfaces are defined to ensure cross-

functional participation in decision making and communication with the customer in their

prescribed format (Ref. APQP).

NA


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2. Automotive leaders shall define communication responsibilities to ensure that appropriate

personnel are informed promptly to take corrective actions on noncompliant products or

processes.

NA

3. Automotive leaders shall utilize formal, comprehensive, documented short- and long-term

business plans which are updated, reviewed and communicated in a controlled manner, track

measures of business plan performance, and are based on current and future customer

expectations. The business plans are controlled documents.

NA

4. Automotive leaders shall ensure that industry level key measurements on trends in quality

and operational performance are gathered and documented (benchmarked) to set priorities to

solve customers immediate and long-term needs and position us versus our competition.

NA

5. Automotive leaders shall establish a documented process to measure, analyze and review

trends in immediate and final customer satisfaction and dissatisfaction for possible action on a

timely basis.

NA

6. Automotive leaders shall notify certification registrar(s) in writing within five working days

when a site has been placed by a customer on a "poor quality" status such as Chrysler "Needs

Improvement", Ford Q-1 Revocation or General Motors Level II Containment,

NA

7. Automotive leaders shall continuously improve quality, service, technology and cost/price. NA


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Score

4.6

5.0

Is rated in 5.5

4.5

IH /Pol. Prev)

NA


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Sample Size.

05.02.01 Objectives and Targets 100%

A. Requirements

1. Responsibility for ownership, development, documentation, maintenance andcommunication of objectives and targets shall be defined.

5

2. Objectives and targets shall be consistent with all company, and respective business,

policies and strategies.

5

3. Objectives, goals and targets for organizations, teams, and employees shall align with

higher level objectives, goals and targets.

5

4. Objectives and targets shall be developed and reviewed with appropriate, considerations

to: measurements, impact analysis, legal & other requirements**, technology, finance,

operations, business requirements, resources, and the views of interested parties, including

customer, community and employee concerns.

5

5. Objectives and targets shall be reviewed, updated, and communicated to all affected

employees at least annually.

5

6. All employees shall be knowledgeable of, and understand, the objectives and targets thataffect them.

5

7. Objectives and targets shall address continuous improvement. 5

B. Legal & Other Requirements**

1. Legal & other requirements to which Dow subscribes shall be identified, interpreted and

made accessible to all affected organizations in the company. Examples may include:

2. Responsible Care

3. ISO-9000

4. ISO-14001

5. Government Regulations

6. Good Manufacturing Practices

7. Customer requirements

8. Internal Dow requirements

9. QS-9000

5


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5.0

5.0

5.0


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Sample Size.

05.02.02 Process Management 89%

A. Requirements

1. Responsibility for the ownership, development, documentation, communication,implementation, improvement and maintenance of processes to facilitate the achievement

5

2. Each process shall be documented using appropriate methodology, which includes role

definitions, enabling technologies, skills & knowledge.

4

3. Global work processes shall be integrated, communicated and implemented to facilitate

efficient use.

4

4. The applicability of global work processes to organizations shall be clearly identified. 4

5. Each organization shall implement applicable, existing global work processes. 4

6. Each organization and department shall determine the local level of detail required for

applicable global work processes.

4

7. Each organization shall evaluate, obtain guidance from the applicable global resource/

expertise center, and implement other appropriate processes not covered by global work

processes.

NR

8. If existing processes do not address all objectives and targets, organizations may, after

reviewing with applicable resource/expertise center, identify and develop the required

processes.

NA

9. Processes shall be evaluated, modified and continuously improved (via MOC process) to

reflect best practices, new developments, new or modified activities, products (especially

special characteristics of products and their associated process parameters) or services,

customer concerns, and any changes in regulations, Dow policies, and/or this company

management system.

4

10. Each organization shall develop prioritized actions plans for continuous improvement in

processes with demonstrated stability, acceptable capability and performance.

5


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Score

4.3

4.3


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Sample Size.

05.03.01 Training 100%

A. Training System Requirements

1. Each organization shall establish a training program to provide applicable, requiredtraining to all employees.

5

2. All employees performing work shall have the training, utilizing appropriate proficiency-

based standards (tests, demonstration of skill, etc...), to satisfactorily complete designated

tasks.

5

3. Training records, including documentation of proficiency achievement, shall be

maintained to comply with applicable Dow, 3rd party, government regulatory, and

organization-specific requirements.

5

4. Training effectiveness shall be periodically reviewed. 5

B. Training Plan Requirements

1. A training needs assessment to identify required training needs (including initial and

refresher training) shall be completed for/by all employees.

5

2. Refresher training and/or proficiency testing frequencies shall be defined to comply withapplicable Dow, 3rd party, government regulatory, and organization-specific requirements.

5

3. A training plan shall exist for each employee based on the training needs assessment. 5

C. Learning Resource Requirements

1. Learning resources, including applicable proficiency demonstration requirements, shall

be defined and accessible.

5

2. Learning resources shall be approved prior to implementation and maintained by

knowledgeable subject matter experts (SME).

4

3. For learning resources implemented with instructors, instructor qualification requirements

shall be defined and documented.

5


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Score

4.9

5.0

5.0

4.7


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Sample Size.

05.03.02 Communication 0

A. Requirements

1. Processes for required internal communications within and between Dows businesses,functions, geographies and work groups shall be established, implemented and maintained.

NR

2. Processes for required external communications with identified contractors, distributors,

suppliers, customers, communities, academics, shareholders, media and appropriate

government and non-government entities shall be established, implemented and maintained.

NR

3. Target audience lists shall be identified, maintained and consistently utilized for required

communications that are coordinated at the company, organization, or work group level.

NR

4. For required communications, the representative viewpoints, concerns, input and feedback of

stakeholders shall be proactively solicited, as applicable.

NR

5. Processes for required communications shall provide the sender and receiver a genuine

opportunity to participate in dialogue, as applicable.

NR

6. Company values, policies, requirements, strategies, objectives, targets, goals, performance

expectations and performance measures shall be communicated to targeted audiences.

NR

7. For external, public policy or internal company-wide communications the Public Affairs

function shall be consulted in order to maximize value and stakeholder impact, and minimize

cost.

NR

8. Plans for projects shall include communication considerations for impacted targeted

audiences.

NR

9. Communications-related training (for example: interpersonal effectiveness and workstation

skills) shall be available to ensure communication system effectiveness.

NR

10. Processes and plans for required communications shall be improved by measuring

communications effectiveness.

NR


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NR

NR


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Sample Size.

05.03.03 Document Management 82%


1. A description of the document organization shall be provided. 52. The process and the roles and responsibilities for creating, revising and controlling

documents shall be defined.

5

3. A master list or equivalent document control procedure identifying the documents and data

that are part of the organizations management system shall be established.

4

4. The document and data control system shall be consistently maintained and used. 4

B. System Requirements

1. The management of change (MOC) process, as defined in a related element of this

management system, shall be used for document and data changes and communication of

changes.

4

2. Documents and data shall be reviewed and approved for adequacy by authorized personnel

prior to issue.

4

3. The revision status and where practical the nature of changes shall be provided for eachdocument.

5

4. Invalid or obsolete documents shall be removed from possible use. 3

5. Obsolete documents retained for legal or knowledge preservation shall be identified as such. NR

6. Current versions of documents shall be available to personnel where needed, including

documents of external origin and currently released editions of documents referenced in

customer drawings or specifications.

5

7. Timely review, distribution and implementation of customer specifications and changes shall

occur.

NR


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4.3

4.5

4.2


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Sample Size.

05.03.04 Procedures 92%


1. Procedures shall be documented, current, accurate, accessible and followed as written for alldesignated tasks.

4

2. Procedures shall be consistent with applicable legal and other requirements. (refer to

Objectives and Targets)

4

3. Procedures shall follow a common format. 54. Employees who perform the work shall be involved in the identification/ development/

maintenance/ improvement of procedures and decisions impacting the frequency of re-training.

5

5. Each procedure shall include: definition of task, task steps, identification of hazards,

description of precautions (including personal protective equipment) and how the procedure

impacts health, safety, quality, operations, and the environment.

5

6. Procedures shall be created and modified by utilizing the MOC process. 5

7. Review of procedures shall occur as often as necessary to ensure each procedure is current

and accurate.

5

8. Review of procedures shall be documented by including the date, name, and description of

the review/change.

5

9. Training and re-training for procedures shall be defined, up-to-date, routinely performed and

records shall be maintained.

5

B. Procedure Use Policy Requirements

1. Each organization shall establish and implement a "Procedure Use Policy" (PUP) which

addresses organization-specific issues/requirements, supplements the information in the global

management system and includes the following, as applicable:

5

2. The PUP shall contain information on the purpose and expectations of procedure usage. 5

3. The PUP shall contain details on responsibilities and requirements for the development,

review, approval, maintenance, correction and improvement of procedures.

5

4. The PUP shall identify designated tasks that require a procedure. 4

5. The PUP shall contain the procedural, documentation and retention requirements for critical

and emergency tasks.

4

6. The PUP shall contain the procedural requirements for non-routine and routine tasks. 5

7. The PUP shall contain the procedural requirements for "first time tasks" (never been

performed before), one time tasks (not expected to be performed again), and tasks for which a

procedure does not exist.

5

8. The PUP shall contain the procedural requirements for inter-business or inter-function

procedures.

NR

9. The PUP shall contain the procedural requirements for the transfer of an on-going procedure

from one group (or shift) to another.

5

10. The PUP shall contain other requirements as necessary to ensure effective and safeoperations.

NR

C. Operating Procedure Requirements

1. Process-related operating procedures shall be clearly identified. 5

2. Operating procedures shall address the following phases of operation (not limited to this list):

Initial start-up, normal operations (including start-up and shutdown), temporary operations,

emergency shutdown, emergency operations, and start-up after a turnaround or emergency

shutdown.

5


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3. Operating procedures shall include the following minimum information: Instructions for

performing steps, safe operating limits, consequences of deviation, steps to correct or avoid

deviation, and safety and health considerations.

5

4. Operating procedures shall be reviewed at least every 3 years. 4

D. Emergency Procedure Requirements

1. Emergency procedures shall be clearly identified. 4

2. Emergency procedures shall be developed and used, as applicable, to address identifiedhazards/situations, methods of response, outside resource capabilities and means of

contact/summons for the following: evacuation, fire, loss of utilities, release, natural events

(hurricanes, tornado, freeze, earthquake, flood), external events (labor disputes, terrorist

activity), and coordination with site emergency plans.

5

3. Due to the potential loss of electronic systems, controlled paper copies of all emergency

procedures shall be maintained at a central, readily-accessible location.

4

4. Emergency procedures shall be reviewed and certified at least annually. 5

5. Emergency procedures training/practice shall be completed at least annually or more often

as determined by each organization.

5

E. Critical Procedure Requirements

1. Critical procedures shall be clearly identified. 4

2. Critical procedures shall be developed and used for all critical tasks, equipment, and unitoperations. 4

3. Critical procedures shall be written in checklist format and contain all procedure information.

(this specifically excludes the use of partial checklists based on a critical procedure. The

procedure and checklist shall be one in the same).

5

4. The person performing a critical task shall have a copy of the critical procedure with them

while performing each step.

NR

5. Completion of each step in a critical procedure shall be clearly indicated by a method

designated in the organizations PUP.

5

6. Completed critical procedures shall be retained by a schedule designated in the

organizations PUP.

4

7. Critical procedures (including critical operating procedures) shall be reviewed/certified at

least annually.

4

8. Knowledge and skills of employees performing critical procedures shall be verified. Re-

training shall be provided at least every 3 years or more frequently if appropriate (based on

performance, incident, etc..).

4

F. Additional Procedure Requirements

1. Procedures related to the identifiable significant environmental aspects of goods and

services used by each organization and department shall be established, maintained, and

followed as written.

5

2. Relevant procedures and requirements shall be communicated to suppliers and contractors

and followed as written.

5

3. Procedures shall be documented and readily available which define the manner of

production, installation, and servicing, where absence of such procedures could adversely

affect quality.

NA


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Score

4.7

4.8

4.8

4.8


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4.6

4.3

5.0

For contractors

For contractors


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Sample Size.

05.03.05 Management of Change 0

A. Implementation Requirements

Each organization or department shall align with the global MOC policy, requirements andprocess by developing a Level 3 procedure to document its implementation of Management of

NR

B. Process Requirements

1. All employees and contractors shall follow the Management of Change (MOC) process for all

changes that are not like-for-like.

NR

2. All changes shall be reviewed to understand the impact on safety, health, loss prevention,

environment, quality, regulatory compliance, reliability, the customer, and other affected

processes.

NR

3. Issues identified from reviews shall be resolved before implementation. NR

4. All changes shall be approved by a second person with the necessary knowledge and skill. NR

5. Within the guidance of the documentation of the Global MOC process, the leader shall

decide the level of knowledge and skills necessary to be able to approve the various changetypes and shall designate those individuals.

NR

6. Training for all people who are expected to interface with or operate a changed process will

occur prior to any interaction they will have with the changed process.

NR

7. All people affected by the change shall be notified prior to any interaction they will have with

the changed process.

NR

8. All critical documentation associated with the execution of the change shall be updated prior

to implementation and placed in the appropriate location for use. All other support

documentation associated with the change shall be updated in a timely manner.

NR

9. All changes shall have records as evidence of compliance with this standard. NR

10. Internal reviews for temporary changes shall be conducted periodically as required. NR

C. Training Requirements

1. All employees and contractors using the MOC process will be trained in its use initially and

be expected to demonstrate proficiency biannually.

NR


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Score

NR

NR

NR

NR


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Sample Size.

05.03.06 Empowerment 100%

A. Requirements

1. Each organization shall evaluate which roles within a work process will be assigned toempowered teams and individuals to create an organizational structure with minimum layers of

4

2. The level of empowerment and the boundaries for roles shall be communicated to individuals

and teams assigned to roles within a work process.

4

3. A process shall be used to ensure effective transfer of tasks from one person to another

during a change.

4

4. Feedback mechanisms shall be established to give all employees the opportunity to input

suggestions for improvement of company management systems, work processes and

performance.

4

5. Processes shall be implemented to recognize and reward individuals and teams. 4


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Score

4.0

4.0


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Sample Size.

05.04.01 Measurements 100%

A. Requirements

1. Responsibility for ownership, development, documentation, maintenance, implementationand improvement of measurement systems shall be defined.

4

2. Process measurements shall be identified and tracked to monitor the performance of work

processes.

4

3. Operational control measurements shall be identified and tracked for

plant/process/department activities. (Examples: Pressure, Temperature, pH, and % analysis of

key component, number of orders entered per CSR, Number of Quality messages).

5

4. Performance measurements for Plant/process/department shall be identified and tracked.

(Examples: yield, lower variability of product attributes, environmental emissions, unit ratios,

invoice accuracy, on time delivery, error free shipments).

4

5. Objectives and Targets measurements shall be identified and tracked.

(Examples of O & T measurement areas: higher asset utilization, environmental waste

reduction, overall product quality, decreased number and severity of safety incidents, customersatisfaction, cost savings.)

5

6. Processes and systems shall be defined and utilized to gather and evaluate measurements

for monitoring on-going activities, and for the identification and prioritization of improvements.

Examples of processes to gather and evaluate measurements include root cause analysis and

statistical analysis.

4

7. All organizations shall identify and document monitoring equipment requiring calibration and

maintenance, and retain records of calibration/maintenance.

5


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Score

4.4

4.4


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Sample Size. Score

05.04.02 Corrective / Preventative Actions 100% 4.3

A. General Requirements 4.3

1. Process and procedures shall be established, implemented and maintained for developing,

implementing and documenting corrective and preventive actions for actual and potentialincidents, unplanned events, non-conformances and customer complaints (whether internal or

external) associated with this company management system.

5

2. Controls shall be established to ensure that corrective and preventive actions are

completed, including documentation of completion and effectiveness.

4

3. Corrective and preventive action taken to eliminate the causes of actual and potential non-

conformances, including the revision of documented procedures and validation of

effectiveness, shall be to a degree appropriate to the magnitude of the problem and the impact

on stakeholders, including customers.

4

4. Steps needed to deal with problems requiring preventive action shall be identified, as

appropriate (refer to Investigations process).

4

5. Preventive actions shall be implemented to prevent additional incidents, unplanned events,

non-conformances and customer complaints as identified in root cause investigations, audits,assessments and other evaluations.

4

6. Relevant information on corrective and preventive actions shall be submitted for

management system review (refer to Management System Review process).

5

B. QS Related Requirements NA

1. Corrective actions shall be implemented to resolve non-conformances using disciplined,

problem-solving methods

NA

2. External non-conformances shall be responded to in a manner prescribed by the customer. NA

3. Mistake-proofing methodology shall be utilized to a degree appropriate to the magnitude of

the problem and risks encountered (QS-9000, Sec. 4.14.1.2).

NA

4. Customer returns shall be analyzed and where appropriate, corrective action and process

changes shall be initiated to prevent recurrence.

NA

5. Corrective action and controls taken to eliminate the cause of a nonconformity shall beapplied to other similar processes and products (QS-9000, Sec. 4.14.2.2). NA

6. Corrective action shall be applied to processes with unacceptable capability/performance. NA


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Sample Size.

05.04.03 Record Management 60%


1. Each organization shall establish and implement procedures (consistent with global processand procedures) for maintaining and controlling all records required within this company

management system.

3

2. Each organization shall assign roles and responsibilities for the process of maintaining and

controlling records.

4

3. Records shall be maintained and controlled to demonstrate effective operation of the

management system and conformance to requirements.

4

4. Records shall be legible and identifiable. 4

5. Records shall be collected, indexed, stored, maintained and controlled for easy access. 4

6. Records shall be protected to prevent damage, deterioration or loss. 4

7. Records shall be made available to the customer when specified by contract. NR

B. Retention and Disposal Requirements

1. Records shall be retained according to established criteria within this document, the

company management system and the Dow Record Retention Manual.

4

2. Records shall be disposed of according to schedules contained in the Dow Record Retention

Manual.

4

3. Each organization and employee shall annually verify that the records within their control are

in conformance to established requirements.

3

4. Quality performance records shall be retained for at least one calendar year after the year in

which they are created.

NR

5. Production Parts Approval Process (PPAP) records shall be maintained for the length of time

that the product is commercially sold, plus one calendar year, unless otherwise specified by the

customer.

NR

6. Superseded product records that are required for new products shall be retained in the newproduct file.

NR

7. Purchase orders shall be kept for at least one year after date of purchase. NR

8. Internal audit and management system review records shall be retained for at least three

years.

NR


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Score

3.8

3.8

3.7


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Sample Size.

05.04.04 Self Assessments 100%

A. Requirements

1. Periodic, routine self-assessments shall be conducted to ensure conformance with anorganizations management systems and Dow, 3rd party, government regulatory and

organization-specific requirements.

4

2. Procedures for self-assessments shall be defined, maintained and accessible. 3

3. Self-assessments shall be scheduled based on requirements, importance of the activity

concerned and the organizations performance in achieving objectives and targets.

3

4. Provisions shall be made to ensure that individuals who conduct self-assessments are

competent (refer to Training element of this management system).

4

5. Results from self-assessments shall be recorded and communicated to those within the

organization responsible for conformance to requirements and achievement of performance

results.

5

6. Deficiencies identified during each self-assessment shall be linked to appropriate resolution

processes defined in other elements of this management system.

4


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3.8

3.8


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Sample Size.

05.04.05 Investigations 0

A. Requirements

1. Processes and procedures shall be established, implemented, improved and maintained toidentify and investigate incidents, unplanned events, continuous improvement opportunities

(including productivity and system quality) and non-conformances.

NR

2. Incidents, unplanned events, opportunities for continuous improvement and non-

conformances, whether internal or external, shall be investigated through root cause analysis,

causes determined, and resolved by emphasizing prevention through root cause analysis.

NR

3. Appropriate sources of information (such as the cost of quality) shall be monitored to detect

events that should be investigated for continuous improvement and analysis and elimination of

the causes of actual and potential non-conformances.

NR

4. Events requiring mandatory investigations using the Global Root Cause Investigation (RCI)

Process and customer specific techniques shall be identified.

NR

5. RCI trigger criteria for significant and potentially significant incidents, unplanned events andnon-conformances shall be established, implemented, reviewed, improved and maintained

within the Global RCI process.

NR

6. Established resolution processes, such as the Corrective and Preventive Action, Resolve

Myself and Behavior-based Performance processes, shall be implemented for continuous

improvement and where necessary to prevent additional incidents, unplanned events, and non-

conformances.

NR

7. Appropriate reporting from investigations shall be made to all stakeholders and involved

parties, including required reporting to government agencies (refer to the Communication

process).

NR

8. Processes potentially important to the customer shall be analyzed. NR

9. Investigation methodology shall demonstrate the knowledge and use of the best practices in

analysis techniques.

NR


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Score

NR

NR


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Sample Size.

05.04.06 Audits 100%

A. Audit Program Requirements

1. The organization shall establish and maintain programs and procedures for periodic audits. 4

C. Audit Procedures Requirements

3. Results from audits shall be recorded and communicated to those within the organization

who are responsible for performance.

5

4. Deficiencies identified during each audit shall be resolved in a timely fashion by utilizing

appropriate resolution processes, such as Corrective Action and MOC.

4


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Score

4.3

4.0

4.5


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Sample Size.

05.05 Management System Review 95%

A. Leadership Requirements

1. Responsibility for development, maintenance and communication of the companysmanagement system review process shall be defined.

NA

2. All required elements of the management system shall be reviewed. 4

3. The scope of each management system review shall be defined based on that portion of the

management system over which the leader has influence and/or control.

5

4. The time intervals for reviews shall be defined appropriate to the scope of each review and at

least once per year.

5

5. The information necessary to carry out an effective review shall be defined and collected 5

6. Review of policies, objectives, targets, and procedures shall be carried out by the level of

leadership that defined each of these systems.

5

7. Appropriate leaders and employees involved in the management and operation of the portion

of the system being reviewed shall participate in the review.

5

8. Each review shall ensure the systems continuing suitability, adequacy and effectiveness in

relation to changing conditions/information and the achievement of objectives and targets,

including performance results.

5

9. A record of each review (including leveraged changes and/or improvements) shall be

created, communicated to appropriate people (including the leaders supervision), and

maintained.

5

B. Review Requirements

1. Each management system review shall consist of comparison and/or evaluation of the

following inputs:

NA

the previous management system review. 5

audit reports, especially systems audits. 5

significant findings from self-assessments and self-inspections. 3 status of preventative, corrective, improvement, and change management actions, compared

to applicable policies, requirements, objectives and targets.

5

the extent to which performance results are meeting objectives and internal and external

targets.

5

the continuing suitability, adequacy and effectiveness of the management system in relation

to changing conditions and information and the opportunity for improvement. Included would be

5

the adequacy of current measurements and resources. 5

concerns and/or satisfaction expressed by relevant interested parties (e.g. customers, public..

etc...).

NR

an analysis of the root causes associated with unplanned events, including the adequacy of

the root cause analysis as it applies to the management system.

5

feedback as to whether leadership support, to meet the needs of the management system, is

being provided.

5

2. In determining actions for improvement, root cause methodology shall be utilized, as

a licable.

5

3. Records of at least the last three Management System Reviews shall be maintained 5


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4. Any actions for improvement which are identified from each review shall be addressed

through appropriate resolution processes, such as established Corrective/Preventative Action,

Management of Change, Objectives and Targets, and/or Communication systems.

5


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Sample Size.

06.01 Community Awareness and Outreach 0


1. Each location shall define and establish working relationships with key stakeholder groups toensure that Dow is recognized as a good neighbor and a valued member of the communities

where we have a presence. At a minimum, key stakeholder groups must include emergency

responders, government officials, the media, the community and local businesses.

NR

2. Each location that manufactures, processes, or distributes chemicals shall establish a

Community Outreach Program that is appropriate to the needs of their location.

NR

B. Community Outreach Program Requirements

1. A practice of openness that provides for convenient ways for interested groups to become

familiar with the facility, its operations, and products, and its efforts to protect safety, health, and

the environment.

NR

2. A process to educate stakeholder groups about:

a. The locations emergency response plan.b. Chemical inventories, emissions and wastes and their risks to the community, including any

impact evaluations.

c. Future plans to reduce waste and emissions and progress in achieving reductions.

d. The locations and facilities process safety systems.

NR

3. Process(es) that ensure a continuing dialogue with:

a. Stakeholder groups to understand their expectations of Dows operations, to address issues

of interest and to respond to questions and concerns about safety, health, environmental

associated with its facilities. This dialogue must include items 2. a, b, c and d as "issues of

interest."

b. State and local emergency planning organizations on the distribution and hazards of the

companys chemicals to improve community preparedness to respond to chemical distribution

emergencies.

c. The public on their concerns about chemical distribution safety, actions taken by the industry

and the company to improve the safety of chemical distribution, and the effectiveness of

emergency preparedness and emergency response assistance.

NR

4. A process for the ongoing assessment of stakeholder groups questions and concerns about

the site and it facilities.

NR

5. A regular evaluation of the effectiveness of the ongoing community outreach efforts. NR


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Score

NR

NR

NR


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Sample Size.

06.02 Distribution and Logistics 0

A. Risk Management Requirements

1. Regular evaluations shall be performed of chemical distribution risks which consider thehazards of the material, the likelihood of accidents/incidents and the potential for human and

environmental exposure from the release of the material over the route of transport.

NR

2. Chemical distribution risk reduction measures shall be implemented that are appropriate to

the risk level.

NR

3. An internal reporting and investigation system of chemical distribution accidents/incidents

and implementation of preventive measures shall be implemented.

NR

B. Compliance Review And Training Requirements

1. Note: Responsible Care Code requirement for management of regulatory requirements,

industry standards, and employee compliance is covered in Section 5.2.1(B) Legal & Other

Requirements.

NR

2. Note: Responsible Care Code requirement for employee training is covered in Section

5.3.1(A) Training System Requirements.

NR

3. A program shall be implemented for providing guidance and information to carriers,

distributors and outside supply chain contractors who perform distribution activities for the

company on the companys training and compliance requirements for the activities.

NR

4. Carrier, distributor and outside supply chain contractors shall be regularly reviewed on their

compliance with applicable regulations and company requirements.

NR

C. Carrier EH&S Requirements

1. A documented process shall be in place for qualifying carriers of all modes and types that

transport materials for or in the name of Dow to and from company facilities that emphasizes

carrier EH&S fitness and regulatory compliance and includes regular reviews of their

performance and compliance.

NR

2. Regular reviews with the carriers on their EH&S performance will be conducted to insure

improvements are being made. These reviews will include EH&S incidents and correctiveactions implemented.

NR

D. Handling and Storage Requirements

1. Documented procedures shall be in place for the selection and use of containers that are

appropriate for the chemical being shipped, in compliance with testing and certification

requirements, and free of leaks and visible defects.

NR

2. Documented procedures shall be in place for loading and unloading chemicals at the

companys facilities that will minimize emissions to the environment, protect personnel and

provide securement of the loading during transit and for safe unloading into proper storage

facilities.

NR

3. Defined criteria shall be established for the cleaning and return of tank cars, tank trucks,

marine vessels and returnable/refillable bulk and semi-bulk containers, and for the proper

disposal of cleaning residues.

NR

4. A process shall be in place for providing guidance and information to customers, distributors,and other receivers on proper procedures for unloading and storing the companys chemicals.

NR

5. A process for selecting and giving feedback shall be in place for distributors and other

facilities that store or handle chemicals in transit that emphasizes EH&S fitness and regulatory

compliance and includes regular reviews of their performance, compliance, and suggestions for

improvement.

NR


64/109

Score

NR

NR

NR

NR

NR


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Sample Size.

06.03 EH&S Engineering Design and Control 0


1. Process route selection and project design and control shall take into account theprinciples of Inherently Safer Process Design.

NR

2. New facilities and those modifications to existing facilities with the potential to impact the

health, safety and the environment shall be designed and constructed to meet the EHS

performance objectives:

Prevent adverse environmental and health impacts

Reduce wastes and emissions and achieve reduction goals

Eliminate persistent, bioaccumulative and toxic emissions to the air and water from our

facilities

NR

Prevent soil and groundwater contamination NR

Prevent Process Safety Incidents such as leaks, spills, fires and explosions NR

Prevent exposure of site personnel (Dow, contractors and visitors) and members of the

community to hazardous chemicals

NR

B. Specific Design Requirements

1. Buildings and Structure Design:

a) Design shall take account separation from hazards and appropriate design to protect

occupants and vital equipment from the effects of hazardous material release (toxic, fire

and explosion).

NR

b) Design shall also allow the proper means of egress and access for emergency

services in emergencies.

NR

2. Chemical Storage Design of chemical storage systems that adequately protect people and

the environment from the effects of spills and leaks.

NR

3. Combustible Dusts: Design shall minimize hazards from combustible dusts and provide

preventative and protective features when there is potential for fire or explosion.

NR

4. Confined Space Entry: Equipment and building design shall take into account the need toavoid where possible the need for Confined Space Entry and facilitate it where it is unavoidable.

NR

5. Electrical: Design shall conform to national codes and local regulations and Dow standards.

Isolation from a safe location in an emergency shall be provided. The hazards of Static

Electricity shall be considered.

NR

6. Emergency Protective Devices and Alarms: Design to meet the requirements for emergency

control and ease of testing.

NR

7. Ergonomics: Design shall minimize exposure to ergonomic stressors that have a significant

potential to result in injuries or illnesses.

NR

8. Equipment General: Design shall conform to Dow Standards and Government requirements

and to minimize fugitive emissions of hazardous and odorous substances and eliminate

excessive noise levels.

NR

9. Fall Prevention: Design to allow all operations which are routinely carried out at heights

where there is potential for injury from falling to be carried out safely without the additional use

of PPE.

NR

10. Fire Protection: The provision of fire protection equipment and systems and their design

shall meet applicable national standards and Dow requirements.

NR

11. Fired Equipment: Design shall use technology that considers burner management

requirements and the possibility of its being a source of ignition during a release.

NR


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12. Flammable Liquids and Gases: Design shall ensure that flammable liquids and gases are

kept out of the flammable or explosive range wherever this is possible.

NR

13. Flares: Design and location of flares shall take account of the degree of environmental

protection required, energy efficiency and noise level, prevention of fires and explosions and the

effects of thermal radiation effects on people and property.

NR

14. Flexible joints in Hazardous Service: Design shall minimize the use in hazardous service.

Where it is necessary design shall include properly designed Flexible joints as being preferredover hoses, bellows and other fragile devices in hazardous service.

NR

15. Fragile Devices in Hazardous Service: Design shall be used to eliminate or minimize the

use of these in hazardous service (e.g. sight glasses, bulls eyes glass or brittle metal piping).

NR

16. Guarding and Interlocking: Design of all rotating, electrical and pressure equipment systems

such that they are safely guarded and where necessary interlocked for personal protection.

NR

17. Laboratory and Analyser Building Safety: Design of laboratories and associated equipment

shall meet applicable national standards. Consideration shall be given to the hazards of

chemical exposure, fires and explosion and the need for control of emissions to the

environment.

NR

18. Leak and Spill Detection/Control/Containment Facilities shall follow the principles laid down in Dow Loss of Primary Containment

(LOPC) requirements

NR

Process areas, including loading, unloading, packaging and storage facilities must be

designed to contain spills and catastrophic equipment failures and direct to a safe

location.

Leak detection, secondary containment and minimization of joints and penetrations

must be included in the design of normally wet sumps and trench systems containing

materials that, if leaked, could result in contamination of soil or groundwater.

NR

19. Loading and Unloading Stations: Design to allow safe access for operations and vehicles,

avoidance of cross contamination and control of spills.

NR

20. Lock out and Red Tag procedures: Design of power supplies for equipment which allow

locking off for locking and Red Tag procedures.

NR

21. Natural Events: Design shall take account of natural events such as storm, flood and

earthquake hazards.

NR

22. Noise: Design shall minimize noise levels emanating from equipment and to prevent

adverse environmental and health impacts to site personnel and the community.

NR

23. Piping: Design of piping and support shall meet national codes and standards and the Dow

Engineering specifications and requirements appropriate to the service and technology.

NR

24. Plant Layout: Design the layout of plant to ensure:

Sufficient separation between hazards and people NR

The possibility of personal injury and knock on effects is minimized. NR

Open air versus indoor construction is reviewed for processes where flammables arehandled.

NR

Access for normal and emergency situations shall be included. NR

25. Pressure Vessels: Design shall conform to applicable governmental codes and Dow

standards with their documentation requirements. Design shall take account of the need to

minimize the potential for soil and groundwater contamination.

NR

26. Process Computers and Data handling equipment: Design and location shall take account

of applicable international standards and the need to protect operations during emergencies.

NR


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27. Process Control and Instrumentation: Design shall conform to government regulations and

the Integrity/reliability requirements laid down in Dow standards.

NR

28. Process vents: Processes must be designed such that Reactive Chemicals incidents and

operation in the flammable range are avoided. (ref Reactive Chemical-Process Hazard Analysis

(RC- PHA) see O.D. - M.S. 6.08).

NR

29. Reactive Chemicals: Design shall include avoidance of Reactive Chemicals incident

potential by addressing isolation, erroneous mixing, equipment failure, prevention of reverseflow and process control.

NR

30. Refrigeration (and Fire Protection) Systems: Design with regard to the use of ozone-

depleting substances shall be consistent with current legislation and Dow standards.

NR

31. Rotating Process Equipment: Design shall take account of the requirements to protect

people the environment and property from the effects of failures by means of design and

monitoring and protective equipment.

NR

32. Safety Relief devices: Design shall conform to national codes and to the Dow Global

Mechanical Integrity Standard. (GMISS) Consideration shall be given to the effect of release to

the environment or routed to a containment, recovery or treatment system.

NR

33. Tanks: Tank foundation must provide a barrier against soil and groundwater contamination. NR

34. Thermal treatment devices: (including thermal oxidizers with and without heat recovery,incinerators, kilns, boilers, furnaces, etc.):

Design must achieve the level of destruction efficiency appropriate for the nature and

volume of materials being treated and/or to meet the level of treatment required or

permitted.

Combustion chambers must provide the necessary temperature, residence time,

turbulence and excess air to achieve the appropriate destruction efficiency.

NR

35. Utility Systems:

Design shall take account of the need to provide safe control of utility systems at point

where they are needed.

NR

S ecial attention shall be desi ned to revent cross contamination of utilit s stems with NR36. Ventilation and Indoor Air: Ventilation systems shall be designed to effectively prevent

overexposure to toxic materials.

NR


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Score

NR

NR

NR


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Sample Size.

06.04 Emergency Preparedness and Response 0

A. Crisis Management Planning

1. The Company and each Area (North America, Latin America, Europe and Pacific) shallestablish a written crisis management plan that includes:

A Crisis Management Operations Center that is equipped with the necessary supporting

equipment to effectively manage a Crisis.

A Crisis Management Team (with alternates).

Team and individual training.

NR

B. Emergency Management Planning

1. A written Emergency Response Contingency Plan shall be established for each Dow facility

which:

Provides for all emergencies that could affect people (Dow and non-Dow) and/or the

environment.

Covers incidents relative to that facility, e.g., Fires, Leaks, Spills, Releases, Explosion, Social

Unrest, Bomb Threats, Severe Weather and Natural Disasters, etc. Provides for and coordinates response, communications and recovery activities with local

communities and neighbors.

Provides for team and individual training to demonstrate proficiency in the handling of

emergencies.

Is integrated with the Corporate/Area Crisis Management Plan.

Is field tested annually.

NR

2. Each location and facility will participate in the community emergency planning process by:

Communicating relevant and useful information to community emergency planners.

Participate in the development and testing of the community emergency response plan.

Sharing of information and experience relating to emergency response planning, exercises,

and the handling of incidents with other facilities in the community.

NR

3. The Company shall maintain an integrated Emergency Response Plan(s) that includes each

location shipping Dow products and all countries through which Dow products are shipped. The

plan(s) shall provide for assistance to outside agencies in the event that Dow products are

involved in a transportation incident.

NR

C. Emergency Response Planning

1. Each location and facility working in concert with the appropriate Emergency Services

organization (location and/or community) must have written emergency response pre-plans that

identify:

Facility/Unit hazards

Emergency Services response times

Emergency responder staffing levels required to minimize loss.

Emergency responder abatement techniques Equipment required

Support resources (Mutual Aid etc.)

Neighbor impact

Links to Incident Command Structure

Links to the Dow Work Processes (for example Operate Plant, Crisis Management work

process)

Any other location specific issue

NR


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2. Each location shall provide facility tours and appropriate training for emergency responders

(location or community) to promote emergency preparedness and to provide current knowledge

of its operations.

NR

D. Emergency Preparedness Planning

1. Each location and facility must ensure the reliability of emergency response equipment, tools

and appliances through regular:

Operational Checks

Inspections

Required Maintenance

Performance testing

Training

Updating Operating Discipline

Record keeping

NR

E. Emergency Response Capability

1. Each location and facility shall have response capabilities available consistent with hazards

present, the extent of fixed protection and the availability of external emergency response. The

capabilities must include as appropriate:

An incident command structure

A communication process to employees, neighbors and government agencies

Fire Fighter responder training.

Confined Space Rescue

High Angle Rescue

Hazmat Response

Distribution Emergency response

Provisions for emergency medical assistance for people at the work site consistent with area

standard of care and requirements

Incident documentation process

Links to the Dow Work Processes (for example Operate Plant, Crisis Management work

process)

NR


78/109

Score

NR

NR

NR

NR


79/109

NR

NR


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Sample Size.

06.05 Employee Health and Safety 82%

A: Identification and Evaluation of Hazards Requirements

1: Job Safety Analysis 32: Exposure Assessment 3

3: Medical Assessment 5

4: Health Promotion Assessment 4

5: Population Health 4

B: Organizational and Individual Expectation Requirements

1: Behavior Based Performance 4

2: Individual Behavior Expectations. 4

3: Employee Participation 4

4: Hazard Awareness 4

5: Medical Care. 4

6: Health Promotion 4

C: Operational Controls and Task Procedures Requirements1: Barricades 4

2: Confined Space Entry 5

3: Electrical Work 4

4: Equipment 4

5: Ergonomics 4

6: Excavations NR

7: Fall Prevention NR

8: Guarding & Interlocking 5

9: Hot Work Standard 5

10: Hydroblasting & Pressure Washing NR

11: Line and Equipment Opening NR

12: Loading and Unloading NR

13: Isolation of Energy Sources (Red Tag) 314: Hearing Conservation 3

15: Operation of Lift Trucks and Lift Devices 4

16: Permit System 5

17: Personal Protective Equipment 3

18: Radiation (Ionizing & Non-ionizing) 4

19: Railroad Operations NR

20: Respiratory Protection 3

21: Safe Operation Of Motor Vehicles And Motorized Handling Equipment 5

22: Thermal Stress (Heat /Cold): 4

23: Ventilation/Indoor Air 2


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Score

3.9

3.8

4.0

3.9


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Sample Size.

06.06 Non Dow Services 0

A. Requirements

1. The Dow organization shall establish and maintain programs and procedures for identifyingcompetitive Non-Dow service providers.

NR

2. The Dow organization shall establish and maintain programs and procedures for selection of

service providers.

NR

3. Prior to the initiation of the service to be provided, the Dow organization shall again

communicate to the selected service provider Dows EH&S expectations and relevant

information to facilitate the achievement of the EH&S expectations. Expectations shall be

consistent with Dow EH&S policies and Responsible Care commitments. Also the service

provider shall be required to provide relevant EH&S information to Dow.

NR

4. The Dow organization shall establish a process to verify that the service provider leadership

has in place a program to regularly observe and measure their EH&S practices.

NR

5. The Dow organization shall establish a program to regularly review the service providersEH&S performance and communicate those findings to the appropriate people and

organizations for the purpose of selecting future service providers.

NR


85/109

Score

NR

NR


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Sample Size.

06.07 Pollution Prevention 59%

A. Waste and Emission Management Requirements

1. An annual waste and emission inventory must be reported in accordance with corporate(environmental) reporting guidelines.

4

2. Each facility must develop a waste and emission reduction plan that is consistent with the

pollution prevention aspects of Responsible Care, that utilizes the waste management hierarchy

(1. Source reduction, 2. Recycle, 3. Recover, 4. Convert, 5. Treatment, 6. Containment) and

that contributes to the goals of Dows waste reduction program.

4

3. The waste and emission management program for each facility must incorporate energy,

water and materials conservation.

2

4. The transfer of emissions from one medium to another for direct discharge or release without

appropriate treatment must not occur.

NA

5. Each location and/or facility must develop and implement procedures for the safe handling

and storage of wastes.

NR

6. Each location and/or facility must implement a standard global process to select, retain and

review of contractors used in the recycling, reclaiming and treatment or disposal of wastes.

NA

7. Each location and/or facility with guidance from functional and business leadership must

have a program for addressing past and present operating and waste management practices

and for working with others, where appropriate, to resolve identified problems at each active or

inactive location owned by Dow.

NA

8. A program must be established that actively promotes and supports employee, community

and industry involvement in waste reduction programs where appropriate.

NR

B. Air Quality Requirements

1. Process vents must be operated to eliminate or reduce process vent emissions of hazardous

substances.

NA

2. Loading and unloading: This requirement is addressed in 6.02 Distribution and Logistics

Requirement, D-2.

NR

3. The emissions of hazardous substances from storage systems must be controlled. NA

4. Leakage from pumps, agitator shafts, compressor shafts, blowers, and other rotating

equipment in hazardous service must be minimized through proper preventive maintenance

and use of appropriate equipment and technology.

5

5. Safety relief devices shall be used only for emergency conditions. Each location and

technology/business must have a program to define the testing and maintenance of safety relief

devices. A risk analysis must be performed to determine if safety relief devices used in handling

hazardous substances should be routed to a recovery or treatment system.

5

6. All fired equipment must be operated in accordance with current Technology Center

requirements. Support fuels with


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8. Flaring of streams, containing halogenated materials, must be evaluated to determine the

feasibility of more desirable options.

NA

9. Cooling water systems that could contact hazardous materials must be controlled to

minimize the risk of process leaks and be monitored for the presence of hazardous substances.

NA

10. The emission of stratospheric ozone-depleting substances from refrigeration and fire

protection systems must be eliminated or minimized.

5

11. Emissions from wastewater streams containing volatile substances must be evaluated with

a goal of reducing emissions to the atmosphere. All wastewater generators shall operate

facilities to reduce chemical releases. Wastewater treatment facilities shall be operated to

minimize air emissions.

NA

12. Odorous emissions should be eliminated but as a minimum must be controlled to meet the

expectations of employees and neighbors and/or applicable regulatory requirements.

NA

13. Each facility must have a fugitive emission monitoring program which operates and

maintains equipment to minimize emissions and must monitor annually a statistically significant

number of fugitive sources.

5

C. Water Quality Requirements

1. Wastewater to treatment plants from facilities must be monitored and controlled to ensure anefficient and effective operation of the wastewater treatment plant. The quantity and quality of

the wastewater must meet predetermined specifications (established between the facility and

the wastewater treatment plant).

5

2. Each location must plan for containment, monitoring and control and, if necessary, treatment

of surface drainage prior to discharge. For processes containing hazardous materials

provisions must be made to minimize the possibility that hazardous chemicals are discharged

to surface waters. Each facility must have a procedure to ensure that containment systems are

maintained and discharges from these systems are monitored and appropriately treated prior to

discharge.

5

3. Storm and fire water drainage must be managed in order to minimize the volume of water

needing treatment while preventing the discharge of untreated contaminated water

NR

4. The use of chromates in cooling towers is prohibited. NA

5. Process wastewater is not to be discharged to conventional septic tanks or to wastewater

treatment plants intended for only sanitary waste, unless preceded by proper in-plant treatment.

NA

6. Spill containment for process, loading, unloading, packaging and storage facilities must be

provided and maintained to protect the treatment plant, surface waters and soil and

groundwater.

4

7. Biological treatment plants, including sludge treatment and disposal, must be operated to

meet the level of treatment defined by technology center or government requirements, and

must be monitored to confirm that destruction efficiencies appropriate for the nature and

volume of materials being treated are achieved.

NA

D. Soil and Groundwater Protection Requirements

1. Each location must evaluate the potential for soil and groundwater contamination. Where

appropriate, a groundwater monitoring program must be established.

NA

2. Each location must develop a containment and/or remediation plan based on an evaluation

of past and current disposal and operational practices to ensure an environmentally sound

location for future use.

NA

3. Underground storage tanks, piping and trenches that have been removed from service must

be evaluated for their long-term environmental risk if they are left to be in the ground.

NA

4. Existing underground storage tanks for chemicals or fuels without leak detection and

secondary containment must be eliminated from service or retrofitted with secondary

containment and leak detection.

NA


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5. For below-grade piping and process sewer installations on Dow locations for materials that, if

leaked, could result in contamination of the soil and groundwater, management systems (e.g.

increased inspections, leak detection, hydrotesting, secondary containment) must be

established to minimize or prevent adverse environmental impact.

NA

6. The operation of cross-country pipelines requires the review and concurrence of the Salt

Mining/Storage/Pipeline Technology Center, the relevant process technology center and

location responsible EH&S person(s).

NA

7. For trenches and sumps for materials that, if leaked, would result in contamination of soil and

groundwater, management systems must be in place to minimize the chance of soil and

groundwater contamination.

NA

8. For existing tanks storing hazardous substances, management systems must be in place to

minimize the chance of soil and groundwater contamination. (Reference: also see 6.03 EH&S

Engineering Design and Controls)

NR

9. Process areas including loading, unloading, packaging and storage facilities must be

maintained to prevent the contamination of soil, groundwater and surface water runoff.

4

10. Spill containment systems for loading/unloading areas must be capable of controlling

potential leaks and spills associated with transfer operations to prevent the contamination of

soil, groundwater and surface water runoff.

4

11. Permanent and temporary areas utilized for the storage or dispensing of materials fromdrums or portable tanks must be capable of containing spills. NR

12. All drilling and piling must be conducted and the installations maintained to avoid potential

vertical migration of contaminating materials. Inactive installations must be closed in an

environmentally appropriate manner.

NA

13. For on-site land disposal activities, management systems must be in place to minimize the

chance of soil and groundwater contamination, including use of operational procedures.

NA

14. The use of surface impoundments for other than water of a quality suitable for discharge

should be avoided.

NA

E. Noise Requirements

1. Facilities must be operated and maintained to control noise below levels that are a nuisance

to surrounding communities.

5

F. Location Aesthetics, Buffer and Conservation Zone Requirements

1. Each location must ensure that painting and housekeeping standards that address location

aesthetics are established and maintained.

NA

2. Each location must ensure that a "green belt" is considered, where space permits and once a

green belt is established, it must be properly maintained.

NA

3. Each location must ensure that appropriate efforts are made to preserve or enhance natural,

ecologically important areas during development and operation of facilities.

NA

G. Contractor and Supplier Evaluation Requirements

1. These requirements are covered in 6.06 Non-Dow Services. NR

H. Subsurface Protection Requirements

1. Deep well disposal of hazardous waste streams is prohibited. However, controlled return of

like-to-like streams -- such as brine, to deep wells in permeable subsurface formations -- is an

acceptable practice.

NA

2. Salt caverns may be utilized for solid waste disposal only after a project review is conducted

jointly by the Environmental and Salt Mining/Storage Technology Centers and written

concurrence is obtained from the Vice President of Operations.

NA

3. Any exception to these specific requirements must obtain written approval from the Vice

President of Operations after review and consent of the Environmental, Health and Safety

Management Board.

NR

4. Every exception to these specific requirements shall be reviewed biannually by the EH&S

Management Board.

NR


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94/109

Score

4.4

3.3

Site!

Site!

5.0


95/109

4.7

4.0


96/109

5.0

NA

NR

NR


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06.08 Process Safety 82%

1. Process Safety Programs

1.1 Risk Management Requirements - Implementation of the Process Risk ManagementStandard level 1 to all facilities

4

1.2 Risk Management Requirements - Implementation of the Process Risk Management

Standard level 2 to all facilities

4



4



4

2. Implementation of the Process Risk Management Standard Hazard and Operability (HAZOP)

2.1 Hazard and Operability (HAZOP) Study NA

3. Process safety Standards and Requirements

3.1 Reactive Chemicals Program 4

3.2 Dow Loss Prevention Principles 43.3 Safety Instrumented Systems complying with Loss Prevention Principle 15.4 4

3.4 Global Mechanical Integrity Safety Standard (GMISS) NR

3.5 Reporting requirements in Global Incident Record Database (GIRD): 5

3.6 Variance is the term to describe the process whereby a facility may not apply a Dow

requirement but has an approved alternative via the Variance Process in the Requirements

Management Work Process.

4


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Score

4.1

4.0

NA

4.2


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Sample Size.

06.09 Product Stewardship 0

A. Product Stewardship Requirements

Each business shall establish a Product Stewardship Program that includes:1. LEADERSHIP: This Requirement is addressed in 5.1 L1R Leadership Responsibilities. NR

2. ACCOUNTABILITY and PERFORMANCE MEASUREMENT: This Requirement is addressed

in 5.1 L1R Leadership Responsibilities.

NR

3. RESOURCES: This Requirement is addressed in 5.1 L1R Leadership Responsibilities. NR

4. HEALTH, SAFETY AND ENVIRONMENTAL INFORMATION: Establishes and maintains

information on health, safety and environmental hazards and on reasonably foreseeable

exposures from new and existing products.

NR

5. PRODUCT RISK CHARACTERIZATION: Characterizes new and existing products with

respect to their risk using information about health, safety and environmental hazards and

reasonably foreseeable exposures. Establishes a system that initiates re-evaluation.

NR

6. RISK MANAGEMENT SYSTEM: Establishes a system to identify, document and implementhealth, safety and environmental risk management actions appropriate to the product risk.

NR

7. PRODUCT AND PROCESS DESIGN IMPROVEMENT: Establishes and maintains a system

that makes health, safety and environmental impacts, including energy and natural resources,

key considerations in designing, developing and improving products and processes.

NR

8. EMPLOYEE EDUCATION AND PRODUCT USE FEEDBACK: Educates and trains

employees, based on job function, on the proper handling, recycling, use and disposal of

products and known product uses. Implements a system that encourages employees to feed

back information on new uses, identified misuses, or adverse effects for use in product risk

characterization.

NR

9. CONTRACT MANUFACTURERS: This Requirement is addressed in 6.06 L1R Non-DowServices. NR

10. SUPPLIERS: Requires suppliers to provide appropriate health, safety and environmental

information and guidance on their products. Factors adherence to sound health, safety and

environmental principles, such as those contained in Responsible Care, into procurement

practices.

NR

11. DISTRIBUTORS: Provides health, safety and environmental information to distributors.

Commensurate with product risk, works with them to foster proper use, handling, recycling,

disposal and transmittal of appropriate information to downstream users. When improper

practices involving a product are discovered, corrective measures should be taken. One option

is to cease doing business with those who are unwilling to implement these measures.

NR

12. CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS: Provides health, safety andenvironmental information to direct product receivers. Commensurate with product risk and

customer sophistication, works with them to foster proper use, handling, recycling, disposal and

transmittal of information to downstream users. When improper practices involving a product

are discovered, corrective measures should be taken. One option is to cease doing business

with those who are unwilling to implement these measures.

NR


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NR


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Sample Size.

06.10 Security 0

A. Access Control and Identification

1. Procedures shall be established at all locations to provide for authorization of people andvehicles accessing Dow facilities. Controlling access to a facility can be achieved by one or

more of the following methods: locks and keys, fences/gates, security personnel, reception

personnel or Dow standard for card access control (required for new or revised systems).

NR

2. Identification documents (IDs/passes) shall be furnished to all people for entry access to all

locations. Displaying IDs/passes is required for entry. Exceptions must be documented.

NR

B. Computer Security

1. Procedures must be established and implemented to ensure that computer systems and the

information they process are operated and maintained in a secure environment.

NR

C. Crime and Fraud

1. Procedures are required for the prevention, detection and investigation of crime and fraud. NR

D. Material Control

1. Procedures are required to control and document material entering and leaving a Dow

location. Typical activities include purchasing, shipping, receiving, storage, salvage, donations,

employee sales, scrap and waste.

NR

2. Separation of authority shall be in place for the following functions: authorizing, approving,

shipping, receiving and payment. Exceptions must be documented and approved.

NR

3. Procurement policies shall be established to determine and detect inappropriate purchases.

Compliance audits are required to assure policies are followed and controlled.

NR

E. Proprietary Information

1. Procedures must be implemented to control Dow proprietary information within Dow and

external to Dow.

NR

2. All Dow employees shall be trained in the proper handling of Dow proprietary information. NR

3. Each Dow location shall have procedures to control the use of cameras and other image

taking devices.

NR

F. Travel

1. All Dow travelers shall have access to current information regarding criminal, social and

political climates of the area to which they may travel.

NR

2. Dow shall maintain a listing of high security risk areas. Anyone traveling outside their home

area (Europe, North America, Latin America, Pacific) to one of these high security risk areas

shall access the Dow Corporate Travel Advisory on the Dow Intranet for the latest information

for their destination.

NR


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