At-Risk Contractor Program

1. At-Risk Contractor Program 2011 Revision

2. At-Risk Definition New to the craft or new to the Dow Freeport site and have been on Site less than 1 year. (Don’t know Dow rules and culture) Experienced in Dow, but new to the contract company. (Don’t know their new companies policies and rules)

3. Purpose of the At-Risk Process Quickly get new employees to learn and live the Dow rules and Safety Culture It is not a program to train workers on their craft – the contractor company does that.

4. At-Risk Employee Data

5. Reason For Change • Data shows that At Risk Employees are 4 times more likely to be involved in an injury incident vs. workers that have 2-5 years experience. (6Sigma JUMP data). • Concerns with insufficient time with Buddy • Contractor feedback indicated need for an updated process • A survey of Buddies and At-Risk contractors was done in late 2010 to collect data on the process. • Feedback from Contractor Managers was also collected.

6. Old Process Previous process consisted of (2) 15 day cycles. Each day consisted of 2 major elements – lots of material to cover in short time The process involved a lot of writing and paperwork. Considered At-Risk for only 90 days One test after (2) 15 day cycles

7. New Process • 2 At Risk Categories • Category 1 – new to Dow or new to craft. New considered less than 1 year • Category 2 – greater than 1 year experience in Dow, but new to company • Category 2 workers may test out

8. New Process All contractors must go through 10 day cycle (Phase 1)regardless of worker type and must pass a test before moving to next phase Office Area workers will go through additional 10 week cycle (Phase 2) and must pass comprehensive test at end of cycle Non-office Area workers must complete 20 week cycle (Phase 2) and must pass comprehensive test at end of cycle Contractors making less than 90% on Phase 1 and 80% on Phase 2 tests will repeat the cycle ( 1 per day, 20 days).

9. New Process 1st 10 day cycle designed to reinforce safety elements deemed very important or critical – culture, elevated work, line of fire, etc. Test added to ensure comprehension of critical elements before moving on to Phase 2. Phase 2 consists of weekly STAC inserts with a single topic for the week. Questions for the topic must be reviewed with Buddy each day. Checklist with outline of elements will continue to be used for reference

10. Example STAC Insert

11. Buddy Qualifications • Work experience in craft and Dow • Exercise safe working practices • Possess good leadership skills • Have interest in mentoring At Risk workers • Good safety and employment record

12. New Process Foreman will update status of At-Risk employee weekly to supervision Company will track status of At-Risk employees and ensure they take the At-Risk tests Orange bands will be worn until final test is passed Contractors are considered At Risk for 3 months for Office Area workers and 6 months for Non Office Area workers

13. Topics Covered (1st 10 Days) At Risk process Culture Emergency Response & Injury reporting PPE Line of Fire Job Planning SWP Elevated Work, Scaffolding Red Tag Severe Violation

14. Questions and Answers Q. What if we currently have a contractor employee in the old At-Risk process do we have to switch?A: No. The old At-Risk test will remain at the safety council until January 2012. Q: When does the new At-Risk process officially start?A: September 1, 2011. However contractors can start using the new process in August as soon as they get the information. Q: Do contractors that took the old At-Risk test need to take the new one?A: No, the old training number on their badge will still be good unless they are gone for more than 1 year.

15. Questions and Answers Q: What if we can’t assign the same buddy all the time?A: Ideally a person would just have one buddy, but that is not always possible depending on the configuration of your company. Your company needs to have people identified as qualified buddies and they need to understand their responsibilities in that capacity. The At-Risk person is responsible for their paperwork and should update the buddy each day (even if it is someone different than the previous day) on where they are in the process. Q: What if our company is new to the site and almost everyone is At-Risk or we will not be on the site long enough to complete the At-Risk process.A: You need to work with your Contractor Safety Contact to develop an alternative method to handle the At-Risk responsibilities. Options may include using Dow or another contractor’s personnel as your buddies, a full time Dow experienced safety person to be with the crew, etc.

16. Questions and Answers Q: What if we are bringing in a new contractor company to Dow or one that has not been here in a long time and all the people will be At-Risk and there is not anyone from the contractor company that could be a buddy – how is that handled?A: The Dow person bringing in the contractor company or the contractor company needs to contact Contractor Safety and an alternative plan will be developed to manage the At-Risk workers.

17. Questions and Answers • Q: What types of questions should a permit writer ask to understand the level of experience of an At-Risk employee?A: 1) How many years have you worked in Dow Freeport? • they may have worked here for years but have switched companies and haven’t taken the test yet. • they may be new to the craft and very inexperienced and this is their first place to work. • they may be very experienced in the craft but have not worked in Freeport before or it has been more than 1 year since they were here. • How many years have you been in your craft? • What day or week are you on in the At-Risk process? What is your topic today/this week? • Who is your buddy?

18. Questions and Answers Q: What are the new At-Risk Tests? A: There will be At-Risk tests at the safety council with 3 badge codes for the At-Risk Program. • Phase 1 At-Risk -10 day • Phase 2 comprehensive for office type workers – 10 week • Phase 2 comprehensive for non-office type workers – 20 week

19. Questions and Answers • Q: What if my facility wants to set limits on the number of At-Risk workers a crew can have?A: • Individual plants will not set their own At-Risk rules so that the Site has consistency and it is not confusing for contractor companies. • Contractor companies will assign crews based on competencies and experience. • The Contractor FIT is working on a database tracking on numbers of At-Risk by company that are typically on site and will evaluate how companies with high turnover are handling the At-Risk process and assigning crews. • The Contractor FIT is requesting At-Risk data for projects and turnarounds. If more than 25% At-Risk are assigned to a project or turnaround the Dow Contact who requested the work is notified. If the Dow Contact has concerns then they should contact their EH&S Delivery Leader for the business who then should discuss with Contractor Safety. • The updated policy will actually have contractors in the At-Risk process longer. • Plants are encouraged to ask questions and escalate concerns to Contractor Supervision, Contractor Safety, or Contractor Operations

20. TOCAS At-Risk Sub-team Tommy Mageors – TIC Safety Mack Wilburn – ATT (TOCAS Sponsor) Jacob Martinez – Miken Safety Bill Radde – Axion Brent Terrill – STS Gus Oros - Unicco Brian Cole – Dow Contractor Safety Ricky Day – Dow Contractor Safety