Texas Operations At-Risk Employee Program Mentor Training

1. Texas OperationsAt-Risk Employee ProgramMentor Training

2. At-Risk Employee Policy • The Dow Chemical Texas Operations At-Risk Employee Policy was created to reduce the number of incidents involving employees who are either new to their craft, new to Dow Texas Operations, or both. • The Policy requires a “Mentor” to be assigned to all At-Risk employees for the duration of the At-Risk Program. • This “Mentor Training” intends to define the mentor process and requirements of a mentor. • Refer to the Related Documents Slide for additional program resources.

3. What is a “Mentor”? • A mentor is an experienced employee of the contractor company who is assigned to work closely with the At-Risk employee. • A mentor assists their company in orienting the At-Risk employee in several areas: • Dow’s safety rules, policies & procedures. • Dow’s safety culture • Company safety rules, policies & procedures. • Craft skills and work practices. • A mentor is also asked to develop, observe and coach the At-Risk employee and report the employee’s progress as well as any issues to the company foreman or supervisor.

4. Mentor Responsibilities • The mentor will become familiar with Dow’s At-Risk Employee policy and checklist and help their company ensure full compliance with the program. • The mentor will communicate Dow’s safety culture of escalating and resolving safety concerns. • The mentor is required to report back to supervision weekly to discuss the progress of the At-Risk employees assigned to them. This discussion should include any problems or concerns that the mentor has about the employee.

5. Mentoring in the field • Data has shown that employees with less than 2 months experience in Dow are at a significantly elevated risk compared to their more experienced co-workers. (data from mid-2011 to mid-2012) # of Incidents

6. Mentoring in the field • The mentor should work VERY closely with the At-Risk employee during the first 2 months. The distance between the mentor and employee at the work site should allow for close observation and communication. As a rule, if the mentor and At-Risk employee can’t see & hear each other, they’re too far apart. • This does not mean that the mentor’s only job is to watch the At-Risk employee. It just means that you should be in a position to observe and quickly intervene with the employee as necessary.

7. Mentoring in the field • Obviously, this distance requirement can be relaxed during non-work times but the employee must be clearly coached on what types of activities are allowed during breaks. • After the first 60 days, if the Mentor and supervisor agree, the distance can be gradually extended and the employee can work more independently. However, direction is still required throughout the duration of the At-Risk program. • At this point the employee’s work scope and duties should still be clearly defined with set boundaries determined by the demonstrated ability to work safely, and craft experience and skill.

8. Mentoring in the field • One of the most important tasks of the mentor is to observe the At-Risk employee in order to identify and intervene on any risky behavior. This risky behavior includes but is not limited to: • Violation of Dow rules. • Violation of company rules, procedures, etc. • Deviation from training or industry best practices. • A poor attitude regarding safety. • Unprofessional behavior including problems with co-workers or supervision.

9. Mentoring in the field • When any of these behaviors are identified, it is the mentor’s responsibility to intervene with the At-Risk employee in order to immediately correct the issue. • If the issue is severe or is not immediately resolved, the mentor is required to escalate the problem to the Foreman, Superintendant, or Safety Contact. The company supervision should then follow their disciplinary process. It is important to quickly identify and report to company supervision employees whose actions indicate that them may not be a fit for this site.

10. Handoffs • Ideally, the At-Risk employee will be assigned one Mentor and be scheduled to work with that Mentor on a day-to-day basis. • If this is not possible, the company must have a program in place to effectively manage the hand-off from one Mentor to another. The new mentor should be made aware of any issues observed with the employee, the employee’s progress in the program etc.

11. > 25% At-Risk • If a company will have a workforce that is >25% At-Risk on site or for a given turnaround or project, the company must document and follow a specific plan to address the situation. Refer to the At-Risk Management Guide on the TOCAS website for options. The plan must be reviewed and approved by the company’s Dow Contractor Safety contact. Ensure that all Mentors and supervisors understand and follow the plan.

12. Related Documents • For further program resources, please visit the TOCAS.org “Management of Change” page for the following documents. • At-Risk Employee Policy • At-Risk Employee Checklist • At-Risk Management Guide

13. Review This document will be reviewed annually by the TOCAS At-Risk Employee Team Revision history The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.