Common Management System

05.01 Leadership Responsibility

5
4
3
2
05.05 Management System Review

05.02 Planning
1
0

05.04 Checking and Corrective Action

05.03 Implementation and Operation

6.0 Responsible Care

06.01 Community Awareness and

Outreach
5.0
06.10 Security

4.0

06.02 Distribution and Logistics

3.0
2.0
06.09 Product Stewardship

06.03 EH&S Engineering Design and

Control

1.0
0.0

06.04 Emergency Preparedness and

Response

06.08 Process Safety

06.07 Pollution Prevention

06.05 Employee Health and Safety

06.06 Non Dow Services

ODMS
05.00 Common Management System
05.01 Leadership Responsibility
05.02 Planning
05.02.01 Objectives and Targets
05.02.02 Process Management
05.03 Implementation and Operation
05.03.01 Training
05.03.02 Communication
05.03.03 Document Management
05.03.04 Procedures
05.03.05 Management of Change
05.03.06 Empowerment
05.04 Checking and Corrective Action
05.04.01 Measurements
05.04.02 Corrective / Preventative Actions
05.04.03 Record Management
05.04.04 Self Assessments
05.04.05 Investigations
05.04.06 Audits
05.05 Management System Review
06.00 Responsible Care
06.01 Community Awareness and Outreach
06.02 Distribution and Logistics
06.03 EH&S Engineering Design and Control
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

4.4

52%

4.5
4.6
4.6
5.0
4.3
4.6
4.9
NR
4.3
4.7
NR
4.0
4.1
4.4
4.3
3.8
3.8
NR
4.3
4.9
4.1
NR
NR
NR
NR
3.9
NR
4.4
4.1
NR
NR

73%
56%
94%
100%
89%
69%
100%
0
82%
92%
0
100%
67%
100%
100%
60%
100%
0
100%
95%
29%
0
0
0
0
82%
0
59%
82%
0
0

Return

Scoring

Sample Size.

05.01 Leadership Responsibility

A. General Requirements
1. Executive leadership shall establish, review, improve and deploy policies, company
strategies and direction and overall performance expectations.
2. Executive leadership shall measure and review the overall companys performance.

56%

NA
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.
6. Leaders shall conduct, with appropriate employee involvement, annual management system
reviews as described further in element 5.5 Management System Review.
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.

5
NR
NR

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

NA

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. Leaders shall establish the boundaries of empowered teams, including specific expectations
and balance of consequences.
C. Automotive Requirements
1. Automotive leaders shall ensure organizational interfaces are defined to ensure crossfunctional participation in decision making and communication with the customer in their
prescribed format (Ref. APQP).

NA

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

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

NA

NA

NA

Score

4.6
5.0

Is rated in 5.5

4.5
IH /Pol. Prev)

NA

Return

Scoring

Sample Size.

05.02.01 Objectives and Targets

A. Requirements
1. Responsibility for ownership, development, documentation, maintenance and
communication of objectives and targets shall be defined.
2. Objectives and targets shall be consistent with all company, and respective business,
policies and strategies.
3. Objectives, goals and targets for organizations, teams, and employees shall align with
higher level objectives, goals and targets.
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. Objectives and targets shall be reviewed, updated, and communicated to all affected
employees at least annually.
6. All employees shall be knowledgeable of, and understand, the objectives and targets that
affect them.
7. Objectives and targets shall address continuous improvement.
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

100%

5
5
5
5

5
5
5
5

Score

5.0
5.0

5.0

Return

Scoring

Sample Size.

05.02.02 Process Management

A. Requirements
1. Responsibility for the ownership, development, documentation, communication,
implementation, improvement and maintenance of processes to facilitate the achievement
of
objectives
andshall
targets
be defined.
2. Each
process
be shall
documented
using appropriate methodology, which includes role
definitions, enabling technologies, skills & knowledge.
3. Global work processes shall be integrated, communicated and implemented to facilitate
efficient use.
4. The applicability of global work processes to organizations shall be clearly identified.
5. Each organization shall implement applicable, existing global work processes.
6. Each organization and department shall determine the local level of detail required for
applicable global work processes.
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.
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.
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.
10. Each organization shall develop prioritized actions plans for continuous improvement in
processes with demonstrated stability, acceptable capability and performance.

89%

5
4
4
4
4
4
NR

NA

Score

4.3
4.3

Return

Scoring

Sample Size.

05.03.01 Training
A. Training System Requirements
1. Each organization shall establish a training program to provide applicable, required
training to all employees.
2. All employees performing work shall have the training, utilizing appropriate proficiencybased standards (tests, demonstration of skill, etc...), to satisfactorily complete designated
tasks.
3. Training records, including documentation of proficiency achievement, shall be
maintained to comply with applicable Dow, 3rd party, government regulatory, and
organization-specific requirements.
4. Training effectiveness shall be periodically reviewed.
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.
2. Refresher training and/or proficiency testing frequencies shall be defined to comply with
applicable Dow, 3rd party, government regulatory, and organization-specific requirements.
3. A training plan shall exist for each employee based on the training needs assessment.
C. Learning Resource Requirements
1. Learning resources, including applicable proficiency demonstration requirements, shall
be defined and accessible.
2. Learning resources shall be approved prior to implementation and maintained by
knowledgeable subject matter experts (SME).
3. For learning resources implemented with instructors, instructor qualification requirements
shall be defined and documented.

100%

5
5

5
5
5

5
4
5

Score

4.9
5.0

5.0

4.7

Return

Scoring

Sample Size.

05.03.02 Communication
A. Requirements
1. Processes for required internal communications within and between Dows businesses,
functions, geographies and work groups shall be established, implemented and maintained.
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
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.
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.
8. Plans for projects shall include communication considerations for impacted targeted
audiences.
9. Communications-related training (for example: interpersonal effectiveness and workstation
skills) shall be available to ensure communication system effectiveness.
10. Processes and plans for required communications shall be improved by measuring
communications effectiveness.

NR

NR

NR
NR
NR

Score

NR
NR

Return

Scoring

Sample Size.

05.03.03 Document Management

A. General Requirements
1. A description of the document organization shall be provided.
2. The process and the roles and responsibilities for creating, revising and controlling
documents shall be defined.
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. The document and data control system shall be consistently maintained and used.
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.
2. Documents and data shall be reviewed and approved for adequacy by authorized personnel
prior to issue.
3. The revision status and where practical the nature of changes shall be provided for each
document.
4. Invalid or obsolete documents shall be removed from possible use.
5. Obsolete documents retained for legal or knowledge preservation shall be identified as such.
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.
7. Timely review, distribution and implementation of customer specifications and changes shall
occur.

82%

5
5
4
4
4

4
5
3
NR
5

NR

Score

4.3
4.5

4.2

Return

Scoring

Sample Size.

05.03.04 Procedures
A. General Requirements
1. Procedures shall be documented, current, accurate, accessible and followed as written for all
designated tasks.

92%

2. Procedures shall be consistent with applicable legal and other requirements. (refer to
Objectives and Targets)
3. Procedures shall follow a common format.
4. 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. 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.
6. Procedures shall be created and modified by utilizing the MOC process.
7. Review of procedures shall occur as often as necessary to ensure each procedure is current
and accurate.
8. Review of procedures shall be documented by including the date, name, and description of
the review/change.
9. Training and re-training for procedures shall be defined, up-to-date, routinely performed and
records shall be maintained.

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:
2. The PUP shall contain information on the purpose and expectations of procedure usage.
3. The PUP shall contain details on responsibilities and requirements for the development,
review, approval, maintenance, correction and improvement of procedures.
4. The PUP shall identify designated tasks that require a procedure.
5. The PUP shall contain the procedural, documentation and retention requirements for critical
and emergency tasks.
6. The PUP shall contain the procedural requirements for non-routine and routine tasks.
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.
8. The PUP shall contain the procedural requirements for inter-business or inter-function
procedures.
9. The PUP shall contain the procedural requirements for the transfer of an on-going procedure
from one group (or shift) to another.
10. The PUP shall contain other requirements as necessary to ensure effective and safe
operations.
C. Operating Procedure Requirements
1. Process-related operating procedures shall be clearly identified.
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
5

5
5
5
5

5
5
4
4
5
5

NR
5
NR

5
5

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.
4. Operating procedures shall be reviewed at least every 3 years.
D. Emergency Procedure Requirements
1. Emergency procedures shall be clearly identified.
2. Emergency procedures shall be developed and used, as applicable, to address identified
hazards/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.
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. Emergency procedures shall be reviewed and certified at least annually.
5. Emergency procedures training/practice shall be completed at least annually or more often
as determined by each organization.
E. Critical Procedure Requirements
1. Critical procedures shall be clearly identified.
2. Critical procedures shall be developed and used for all critical tasks, equipment, and unit
operations.
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).
4. The person performing a critical task shall have a copy of the critical procedure with them
while performing each step.
5. Completion of each step in a critical procedure shall be clearly indicated by a method
designated in the organizations PUP.
6. Completed critical procedures shall be retained by a schedule designated in the
organizations PUP.
7. Critical procedures (including critical operating procedures) shall be reviewed/certified at
least annually.
8. Knowledge and skills of employees performing critical procedures shall be verified. Retraining shall be provided at least every 3 years or more frequently if appropriate (based on
performance, incident, etc..).
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.
2. Relevant procedures and requirements shall be communicated to suppliers and contractors
and followed as written.
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.

4
4
5

4
5
5

4
4
5

NR
5
4
4
4

5
NA

Score

4.7
4.8

4.8

4.8

4.6

4.3

5.0
For contractors

For contractors

Return

Scoring

Sample Size.

05.03.05 Management of Change

A. Implementation Requirements
Each organization or department shall align with the global MOC policy, requirements and
process by developing a Level 3 procedure to document its implementation of Management of
Change
(MOC)
as described in the Global MOC Standard (refer to MOC Web Site).
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.
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.
3. Issues identified from reviews shall be resolved before implementation.
4. All changes shall be approved by a second person with the necessary knowledge and skill.
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 change
types and shall designate those individuals.
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.
7. All people affected by the change shall be notified prior to any interaction they will have with
the changed process.
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.
9. All changes shall have records as evidence of compliance with this standard.
10. Internal reviews for temporary changes shall be conducted periodically as required.
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

NR
NR

NR
NR
NR

NR
NR
NR

NR
NR
NR

Score

NR
NR

NR

NR

Return

Scoring

Sample Size.

05.03.06 Empowerment
A. Requirements
1. Each organization shall evaluate which roles within a work process will be assigned to
empowered teams and individuals to create an organizational structure with minimum layers of
management,
decision-making
is decentralized
and shall
decisions
are made closest
to the
2. The level of where
empowerment
and the boundaries
for roles
be communicated
to individuals
and teams assigned to roles within a work process.
3. A process shall be used to ensure effective transfer of tasks from one person to another
during a change.
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.
5. Processes shall be implemented to recognize and reward individuals and teams.

100%

4
4
4
4

Score

4.0
4.0

Return

Scoring

Sample Size.

05.04.01 Measurements
A. Requirements
1. Responsibility for ownership, development, documentation, maintenance, implementation
and improvement of measurement systems shall be defined.
2. Process measurements shall be identified and tracked to monitor the performance of work
processes.
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).
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).
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, customer
satisfaction, cost savings.)
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.
7. All organizations shall identify and document monitoring equipment requiring calibration and
maintenance, and retain records of calibration/maintenance.

100%

4
4
5

Score

4.4
4.4

Sample Size.

05.04.02 Corrective / Preventative Actions

A. General Requirements
1. Process and procedures shall be established, implemented and maintained for developing,
implementing and documenting corrective and preventive actions for actual and potential
incidents, unplanned events, non-conformances and customer complaints (whether internal or
external) associated with this company management system.

100%

4.3

3. Corrective and preventive action taken to eliminate the causes of actual and potential nonconformances, 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. Steps needed to deal with problems requiring preventive action shall be identified, as
appropriate (refer to Investigations process).

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.
6. Relevant information on corrective and preventive actions shall be submitted for
management system review (refer to Management System Review process).

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).
4. Customer returns shall be analyzed and where appropriate, corrective action and process
changes shall be initiated to prevent recurrence.
5. Corrective action and controls taken to eliminate the cause of a nonconformity shall be
applied to other similar processes and products (QS-9000, Sec. 4.14.2.2).
6. Corrective action shall be applied to processes with unacceptable capability/performance.

4.3

2. Controls shall be established to ensure that corrective and preventive actions are
completed, including documentation of completion and effectiveness.

B. QS Related Requirements
1. Corrective actions shall be implemented to resolve non-conformances using disciplined,
problem-solving methods
2. External non-conformances shall be responded to in a manner prescribed by the customer.

Score

5
NA
NA
NA
NA
NA
NA
NA

Return

Scoring

Sample Size.

05.04.03 Record Management

A. General Requirements
1. Each organization shall establish and implement procedures (consistent with global process
and procedures) for maintaining and controlling all records required within this company
management system.

60%

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

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

management system and conformance to requirements.

4. Records shall be legible and identifiable.

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

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

7. Records shall be made available to the customer when specified by contract.
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.
2. Records shall be disposed of according to schedules contained in the Dow Record Retention
Manual.
3. Each organization and employee shall annually verify that the records within their control are
in conformance to established requirements.
4. Quality performance records shall be retained for at least one calendar year after the year in
which they are created.
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.
6. Superseded product records that are required for new products shall be retained in the new
product file.
7. Purchase orders shall be kept for at least one year after date of purchase.
8. Internal audit and management system review records shall be retained for at least three
years.

4
NR
4
4
3
NR
NR

NR
NR
NR

Score

3.8
3.8

3.7

Return

Scoring

Sample Size.

05.04.04 Self Assessments

A. Requirements
1. Periodic, routine self-assessments shall be conducted to ensure conformance with an
organizations management systems and Dow, 3rd party, government regulatory and
organization-specific requirements.
2. Procedures for self-assessments shall be defined, maintained and accessible.

100%

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

concerned and the organizations performance in achieving objectives and targets.

4. Provisions shall be made to ensure that individuals who conduct self-assessments are
competent (refer to Training element of this management system).

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.
6. Deficiencies identified during each self-assessment shall be linked to appropriate resolution
processes defined in other elements of this management system.

Score

3.8
3.8

Return

Scoring

Sample Size.

05.04.05 Investigations
A. Requirements
1. Processes and procedures shall be established, implemented, improved and maintained to
identify and investigate incidents, unplanned events, continuous improvement opportunities
(including productivity and system quality) and non-conformances.
2. Incidents, unplanned events, opportunities for continuous improvement and nonconformances, whether internal or external, shall be investigated through root cause analysis,
causes determined, and resolved by emphasizing prevention through root cause analysis.

NR

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.
4. Events requiring mandatory investigations using the Global Root Cause Investigation (RCI)
Process and customer specific techniques shall be identified.
5. RCI trigger criteria for significant and potentially significant incidents, unplanned events and
non-conformances shall be established, implemented, reviewed, improved and maintained
within the Global RCI process.
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 nonconformances.
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.

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

NR
NR

NR
NR

NR

NR

Score

NR
NR

Return

Scoring

Sample Size.

05.04.06 Audits
A. Audit Program Requirements
1. The organization shall establish and maintain programs and procedures for periodic audits.
C. Audit Procedures Requirements
3. Results from audits shall be recorded and communicated to those within the organization
who are responsible for performance.
4. Deficiencies identified during each audit shall be resolved in a timely fashion by utilizing
appropriate resolution processes, such as Corrective Action and MOC.

100%

5
4

Score

4.3
4.0

4.5

Return

Scoring

Sample Size.

05.05 Management System Review

A. Leadership Requirements
1. Responsibility for development, maintenance and communication of the companys
management system review process shall be defined.
2. All required elements of the management system shall be reviewed.
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.
4. The time intervals for reviews shall be defined appropriate to the scope of each review and at
least once per year.
5. The information necessary to carry out an effective review shall be defined and collected
6. Review of policies, objectives, targets, and procedures shall be carried out by the level of
leadership that defined each of these systems.
7. Appropriate leaders and employees involved in the management and operation of the portion
of the system being reviewed shall participate in the review.
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.
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.
B. Review Requirements
1. Each management system review shall consist of comparison and/or evaluation of the
following inputs:
the previous management system review.
audit reports, especially systems audits.
significant findings from self-assessments and self-inspections.
status of preventative, corrective, improvement, and change management actions, compared
to applicable policies, requirements, objectives and targets.
the extent to which performance results are meeting objectives and internal and external
targets.
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
the
relevance
of of
policies,
targets,
the
adequacy
currentobjectives,
measurements
andprocesses
resources.and implementation priorities.
concerns and/or satisfaction expressed by relevant interested parties (e.g. customers, public..
etc...).
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.
feedback as to whether leadership support, to meet the needs of the management system, is
being provided.
2. In determining actions for improvement, root cause methodology shall be utilized, as
applicable.
3. Records of at least the last three Management System Reviews shall be maintained

95%

NA
4
5
5
5
5
5
5

NA
5
5
3
5
5
5
5
NR
5
5
5
5

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.

Score

4.9
4.9

4.8

Return

Scoring

Sample Size.

06.01 Community Awareness and Outreach

A. General Requirements
1. Each location shall define and establish working relationships with key stakeholder groups to
ensure 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.
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.
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.
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.
5. A regular evaluation of the effectiveness of the ongoing community outreach efforts.

NR

NR

NR

NR

NR

Score

NR
NR

NR

Return

Scoring

Sample Size.

06.02 Distribution and Logistics

A. Risk Management Requirements
1. Regular evaluations shall be performed of chemical distribution risks which consider the
hazards 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.
2. Chemical distribution risk reduction measures shall be implemented that are appropriate to
the risk level.
3. An internal reporting and investigation system of chemical distribution accidents/incidents
and implementation of preventive measures shall be implemented.
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.
2. Note: Responsible Care Code requirement for employee training is covered in Section
5.3.1(A) Training System Requirements.
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.
4. Carrier, distributor and outside supply chain contractors shall be regularly reviewed on their
compliance with applicable regulations and company requirements.
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.
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 corrective
actions implemented.
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.
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.
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.
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.
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

NR
NR

NR

NR
NR

NR

NR

NR

NR

NR

NR

NR

NR

Score

NR
NR

NR

NR

NR

Return

Scoring

Sample Size.

06.03 EH&S Engineering Design and Control

A. General Requirements
1. Process route selection and project design and control shall take into account the
principles of Inherently Safer Process Design.
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
NR

Prevent soil and groundwater contamination

Prevent Process Safety Incidents such as leaks, spills, fires and explosions
Prevent exposure of site personnel (Dow, contractors and visitors) and members of the
community to hazardous chemicals
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).
b) Design shall also allow the proper means of egress and access for emergency
services in emergencies.
2. Chemical Storage Design of chemical storage systems that adequately protect people and
the environment from the effects of spills and leaks.
3. Combustible Dusts: Design shall minimize hazards from combustible dusts and provide
preventative and protective features when there is potential for fire or explosion.
4. Confined Space Entry: Equipment and building design shall take into account the need to
avoid where possible the need for Confined Space Entry and facilitate it where it is unavoidable.

NR
NR
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.
6. Emergency Protective Devices and Alarms: Design to meet the requirements for emergency
control and ease of testing.
7. Ergonomics: Design shall minimize exposure to ergonomic stressors that have a significant
potential to result in injuries or illnesses.
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.
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.
10. Fire Protection: The provision of fire protection equipment and systems and their design
shall meet applicable national standards and Dow requirements.
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

NR

NR
NR
NR
NR

NR
NR
NR

NR

NR
NR

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.
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.
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 preferred
over hoses, bellows and other fragile devices in hazardous service.
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.
18. Leak and Spill Detection/Control/Containment
Facilities shall follow the principles laid down in Dow Loss of Primary Containment
(LOPC) requirements
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.
20. Lock out and Red Tag procedures: Design of power supplies for equipment which allow
locking off for locking and Red Tag procedures.
21. Natural Events: Design shall take account of natural events such as storm, flood and
earthquake hazards.
22. Noise: Design shall minimize noise levels emanating from equipment and to prevent
adverse environmental and health impacts to site personnel and the community.
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
The possibility of personal injury and knock on effects is minimized.
Open air versus indoor construction is reviewed for processes where flammables are
handled.
Access for normal and emergency situations shall be included.
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.
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

NR

NR

NR
NR

NR
NR
NR
NR

NR
NR
NR
NR
NR

NR

27. Process Control and Instrumentation: Design shall conform to government regulations and
the Integrity/reliability requirements laid down in Dow standards.
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).
29. Reactive Chemicals: Design shall include avoidance of Reactive Chemicals incident
potential by addressing isolation, erroneous mixing, equipment failure, prevention of reverse
flow and process control.
30. Refrigeration (and Fire Protection) Systems: Design with regard to the use of ozonedepleting substances shall be consistent with current legislation and Dow standards.
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.
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.
33. Tanks: Tank foundation must provide a barrier against soil and groundwater contamination.
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.
35. Utility Systems:
Design shall take account of the need to provide safe control of utility systems at point
where they are needed.
Special attention shall be designed to prevent cross contamination of utility systems with
36. Ventilation and Indoor Air: Ventilation systems shall be designed to effectively prevent
overexposure to toxic materials.

NR
NR

NR

NR
NR

NR

NR

NR

NR
NR
NR

Score

NR
NR

NR

Return

Scoring

Sample Size.

06.04 Emergency Preparedness and Response

A. Crisis Management Planning
1. The Company and each Area (North America, Latin America, Europe and Pacific) shall
establish 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.
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

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.
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

NR

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.
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
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

NR

NR

Score

NR
NR

NR

NR

NR

NR

Return

Scoring

Sample Size.

06.05 Employee Health and Safety

A: Identification and Evaluation of Hazards Requirements
1: Job Safety Analysis
2: Exposure Assessment
3: Medical Assessment
4: Health Promotion Assessment
5: Population Health
B: Organizational and Individual Expectation Requirements
1: Behavior Based Performance
2: Individual Behavior Expectations.
3: Employee Participation
4: Hazard Awareness
5: Medical Care.
6: Health Promotion
C: Operational Controls and Task Procedures Requirements
1: Barricades
2: Confined Space Entry
3: Electrical Work
4: Equipment
5: Ergonomics
6: Excavations
7: Fall Prevention
8: Guarding & Interlocking
9: Hot Work Standard
10: Hydroblasting & Pressure Washing
11: Line and Equipment Opening
12: Loading and Unloading
13: Isolation of Energy Sources (Red Tag)
14: Hearing Conservation
15: Operation of Lift Trucks and Lift Devices
16: Permit System
17: Personal Protective Equipment
18: Radiation (Ionizing & Non-ionizing)
19: Railroad Operations
20: Respiratory Protection
21: Safe Operation Of Motor Vehicles And Motorized Handling Equipment
22: Thermal Stress (Heat /Cold):
23: Ventilation/Indoor Air

82%

3
3
5
4
4
4
4
4
4
4
4
4
5
4
4
4
NR
NR
5
5
NR
NR
NR
3
3
4
5
3
4
NR
3
5
4
2

Score

3.9
3.8

4.0

3.9

Return

Scoring

Sample Size.

06.06 Non Dow Services

A. Requirements
1. The Dow organization shall establish and maintain programs and procedures for identifying
competitive 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.
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 providers
EH&S performance and communicate those findings to the appropriate people and
organizations for the purpose of selecting future service providers.

NR

NR

Score

NR
NR

Return

Scoring

Sample Size.

06.07 Pollution Prevention

A. Waste and Emission Management Requirements
1. An annual waste and emission inventory must be reported in accordance with corporate
(environmental) reporting guidelines.
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.
3. The waste and emission management program for each facility must incorporate energy,
water and materials conservation.
4. The transfer of emissions from one medium to another for direct discharge or release without
appropriate treatment must not occur.
5. Each location and/or facility must develop and implement procedures for the safe handling
and storage of wastes.

59%

4
4

2
NA
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.
8. A program must be established that actively promotes and supports employee, community
and industry involvement in waste reduction programs where appropriate.

NA

B. Air Quality Requirements

1. Process vents must be operated to eliminate or reduce process vent emissions of hazardous
substances.
2. Loading and unloading: This requirement is addressed in 6.02 Distribution and Logistics
Requirement, D-2.
3. The emissions of hazardous substances from storage systems must be controlled.

NR

NA
NR
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. 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.

6. All fired equipment must be operated in accordance with current Technology Center
requirements. Support fuels with <1% Sulfur should be used. NOx generation must be
minimized using the appropriate technology. Carbon monoxide monitoring should be evaluated.

NA

7. Devices used for thermal treatment (including thermal oxidizers with and without heat
recovery, incinerators, kilns, boilers, furnaces, etc.) 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

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

feasibility of more desirable options.
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.
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.
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.

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.
C. Water Quality Requirements
1. Wastewater to treatment plants from facilities must be monitored and controlled to ensure an
efficient 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).
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.
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
4. The use of chromates in cooling towers is prohibited.
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.
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.
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.
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.
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.
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.
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

NA

NA

NR
NA
NA

NA

NA
NA

NA
NA

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.
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).
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.
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)
9. Process areas including loading, unloading, packaging and storage facilities must be
maintained to prevent the contamination of soil, groundwater and surface water runoff.
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.
11. Permanent and temporary areas utilized for the storage or dispensing of materials from
drums or portable tanks must be capable of containing spills.
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.
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.
14. The use of surface impoundments for other than water of a quality suitable for discharge
should be avoided.
E. Noise Requirements
1. Facilities must be operated and maintained to control noise below levels that are a nuisance
to surrounding communities.
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.
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.
3. Each location must ensure that appropriate efforts are made to preserve or enhance natural,
ecologically important areas during development and operation of facilities.
G. Contractor and Supplier Evaluation Requirements
1. These requirements are covered in 6.06 Non-Dow Services.
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.
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.
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.
4. Every exception to these specific requirements shall be reviewed biannually by the EH&S
Management Board.

NA

NA

NA

NR

4
4

NR
NA

NA

NA

NA
NA
NA

NR
NA

NA

NR

NR

Score

4.4
3.3

Site!

Site!

5.0

4.7

4.0

5.0

NA

NR
NR

Return

Scoring

Sample Size.

06.08 Process Safety

1. Process Safety Programs
1.1 Risk Management Requirements - Implementation of the Process Risk Management
Standard level 1 to all facilities
1.2 Risk Management Requirements - Implementation of the Process Risk Management
Standard level 2 to all facilities
1.3 Risk Management Requirements - Implementation of the Process Risk Management
Standard level 3 to all facilities
1.4 Risk Management Requirements - Implementation of the Process Risk Management
Standard level 4 to all facilities

82%

4
4
4
4

2. Implementation of the Process Risk Management Standard Hazard and Operability (HAZOP) Study for all technology new to
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
4
3.3 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
4
requirement but has an approved alternative via the Variance Process in the Requirements
Management Work Process.

Score

4.1
4.0

NA
4.2

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Scoring

Sample Size.

06.09 Product Stewardship

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.
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 implement

health, 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.
9. CONTRACT MANUFACTURERS: This Requirement is addressed in 6.06 L1R Non-Dow
Services.

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 and
environmental 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

NR

NR

Score

NR
NR

Return

Scoring

Sample Size.

06.10 Security
A. Access Control and Identification
1. Procedures shall be established at all locations to provide for authorization of people and
vehicles 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).
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.
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.
C. Crime and Fraud
1. Procedures are required for the prevention, detection and investigation of crime and fraud.
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.
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

NR

NR

NR
NR

NR

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

Compliance audits are required to assure policies are followed and controlled.
E. Proprietary Information
1. Procedures must be implemented to control Dow proprietary information within Dow and
external to Dow.
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.
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.
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

NR
NR

NR
NR

Score

NR
NR

NR

NR
NR

NR

NR