Beruflich Dokumente
Kultur Dokumente
Verification Report
Dow Chemical Canada ULC
December 16, 2010
Disclaimer
This report has been produced by a team, convened by the Chemistry Industry Association of
Canada (CIAC), to provide advice to the member-company and assist it in meeting its
Responsible Care commitments. The material in this report reflects the team's best judgment in
light of the information available to it at the time of preparation. It is the responsibility of the
CIAC member-company that is the subject of this report to interpret and act on the reports
findings and recommendations as it sees fit. Any use which a third party makes of this document,
or any reliance on the document or decisions made based upon it, are the responsibility of such
third parties. Although CIAC members are expected to share the results of this guidance
document with interested parties, the Association, its member-companies, their employees,
consultants and other participants involved in preparing the document accept no responsibility
whatsoever for damages, if any, suffered by a third party as a result of decisions made or actions
based on this report.
Responsible Care is a registered trademark of the Chemistry Industry Association of
Canada.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 2 of 37
Signed:
Verification Team Leader
For more information on this or a previous Responsible Care Verification Report, please
contact your local company site or the companys overall Responsible Care coordinator:
Elaine Wasylenchuk, EH&S Regulatory Affairs Specialist
(780)998-8015
ewasylenchuk@dow.com
www.dowcanada.com
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 3 of 37
The detailed process safety near miss reporting which requires that such items as all safety
valve openings are reported and formally investigated.
The Scenarios of Significance process in place at the Fort Saskatchewan facility, which
identifies potential incident scenarios and use of this information for emergency
preparedness event planning.
Use of a Sustainable Chemistry Index to help measure progress (with a defined target) in
improving product portfolios to become more sustainable.
While not by Dow in Canada, the decision taken to manufacture chlorine in California rather
than doing so in the Gulf of Mexico area and shipping it to California. An example of a
positive contribution to the Dow Chemical 2015 goal of reducing shipment tonne miles by
50%.
The company requirement to internally report, and investigate these to prevent recurrence,
all spills over 50 kilograms even if non-hazardous or within secondary containment, This
helps to create a zero spills attitude among all personnel.
Significant focus on greenhouse gas emissions and water usage management.
The pre-job task analysis process which includes routine and non-routine work related to
process operations, maintenance, laboratory activities, office work, driving, and travel.
The membership, dialogue, level of engagement and trust within the Community Advisory
Panels in place at the Prentiss, Fort Saskatchewan and West Hill facilities.
The Change Maker Audit program whereby entire audits of jobs in progress are undertaken
by trained staff on a scheduled basis.
The use of contracted qualified safety professionals to act as safety watches during
turnarounds, as opposed to the traditional approach of hiring general contract employees
and providing them with the minimum basic training to carry out this work.
The West Hill site process to, at defined intervals, personally contact neighbours who could
be impacted by a site incident, advising them as to site risks and what to do in an
emergency.
Dows appreciation to the Sarnia community, following the closure of their significant
operating facilities, expressed with sensitivity by involving community representatives in the
selection of a legacy project, the Youth Centre, as well as in donating their existing
wetlands venture to the St. Clair Region Conservation Authority.
Dow AgroSciences R & D focus on Sustainability via developing agricultural seeds and
traits which will reduce insecticide, nutrient and water usage while yielding crops at
increased productivity, which are better for human health.
Dows publicly stated stretch 2015 Sustainability commitments and Dow Canadas
organizational alignment and commitment towards their achievement.
Dows Decommissioning and Demolition process.
Complete current plans at the Rohm & Haas West Hill site to complete a layers of
protection analysis (LOPA) by the current targeted completion in 2011
Complete the planned company crisis management plan exercise by the scheduled date in
2011.
At the Varennes site, complete their project to upgrade the shavings extraction and filtration
process to a bag filter system by the targeted completion of Q1, 2012. This will not only
reduce shavings emissions but also reduce operating area noise level exposures.
New Opportunities Persons doing self assessments should consider including individuals from other areas to
bring a broader perspective to the review.
At Dow AgroSciences Canadas Saskatoon site, establish a process to ensure that followup actions from all activities (e.g., Management of Change (MOC) reviews, Event and
Action Tool (E&AT) actions, Environment, Safety and Health (EH&S) self-assessments,
Behaviour Based Performance (BBP) items) are completed as scheduled.
The Varennes site are encouraged to develop and implement a formalized management
system to ensure that local and Provincial regulatory changes are identified at an early
stage of development
At all facilities, identify all affected stakeholders for communication of re-verification reports
(e.g., local neighbours, emergency services. local government, etc.) not just the CAP.
Establish a process to ensure that the closure on action items for the Event & Action Tool
address the root causes of the issues, not just the surface fix.
Consider raising the profile of the companys current leading performance indicators (i.e.,
activities with a proactive preventive focus) by sharing key results with employees and
leadership, similar to what is done at Prentiss.
Establish a plan detailing how all company sites might move to the Enhanced and
Excellent levels of process safety, according to the CIAC High Inventory Site Assessment
(HISAT) Tool. Document the rationale where any decision has been made not to move to
higher levels.
Establish a process to ensure that all operating procedures at the Prentiss Site are updated
according to schedule. A number were noted as being beyond their review target date.
Consider inserting a requirement into supplied service contracts to carry out background
checks on all contract employees, in key positions identified by Dow, coming to company
facilities.
Consider implementing, at all manufacturing sites, the Scenarios of Significance process in
place at the Fort Saskatchewan facility, to identify potential incident scenarios for use in
emergency preparedness event planning.
In collaboration with local authorities and in consultation with the companys Community
Advisory Panels, at all sites, establish a process to test, through to its conclusion, the
community emergency call system to potentially impacted neighbours (i.e., not just a test of
the call system technology but to check that people have actually been contacted and
advised what to do).
In collaboration with the local authorities and in consultation with those potentially affected,
check the effectiveness of the emergency notification process for people working in fields
surrounding the Prentiss site.
Build severe weather complications into site emergency exercise scenarios (e.g., people
exposures to heat or cold, response equipment breakdown/unavailable due to freezing/bad
road conditions, etc.).
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 6 of 37
The Varennes site are encouraged to have their updated site impact assessments
externally validated and then communicated to local responders and the impacted
community.
The Varennes site are encouraged to validate that nearby loaded rail cars would not be
impacted by a significant Styrofoam fire incident.
Periodically meet with local hospital emergency staff for information sharing on potential
injuries and exposures to employees, the extent of support possibly being required during
emergency events, emergency communications etc.
o Note: Some activity has taken place on such information sharing in Fort
Saskatchewan.
Establish organizational links in Canada to the supply chain services provided from the
United States to ensure that CIAC Responsible Care aspects are appropriately addressed
in all activities (e.g., transportation, warehousing, distributors, etc.).
An improvement opportunity is to ensure that one of the planned semi-annual fugitive
emission surveys at Dow Chemical sites be performed shortly after start-ups following
maintenance shutdowns.
Upgrade the Prentiss site visitor orientation video to promote Responsible Care similar to
that which is understood to exist in the Fort Saskatchewan site video.
Enhance Responsible Care visibility both inside and outside the company by adding the
logo and attendant wording to documentation (e.g., business cards, letterhead,
presentation templates, supplier and sales documentation, etc.).
To enhance awareness of Responsible Care, establish a specific (by name) orientation
session for new employees and contractors, and an update for existing employees, that
reviews the Ethic, Principles and Codes of Practice, how the company complies with these
requirements through its ODMS etc.
Note: The model developed by Dows overall Responsible Care Coordinator during the reverification visits could serve as an excellent tool for widespread use in this regard.
At the Prentiss site, consider checking to ensure that contractor employees feel free to
report unsafe situations within their own companies.
o (Note: During an informal discussion, one contract individual indicated some
difficulty with this.)
With 50% of site business incidents currently involving fork lift trucks, the Varennes site are
encouraged to complete their planned projects to double the size of their finished product
storage area and improve storage and loading area lighting by their Q3,2011 completion
target.
The Varennes site is encouraged to improve their Industrial Hygiene monitoring system as
detailed in the November, 2010 corporate audit.
At the next community site operations risk communication at the Fort Saskatchewan facility,
scheduled for 2011, ensure that, as well as general communications, direct contact is made
with all Dow neighbours who may be impacted, with information on the nature of the
potential impact and what to do in an emergency.
In future community site risk communications include a test of knowledge regarding shelter
in place.
The Varennes site are encouraged to communicate their updated site risk information to
potentially impacted neighbours upon completion of the external risk assessment validation
which was to commence shortly after the re-verification site visit.
Consider including representatives of the companys Community Advisory Panels in annual
Responsible Care related management system reviews.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 7 of 37
1.
1a)
The company
This is the report by the verification team on those operations of Dow Chemical Canada ULC,
Dow AgroSciences Canada Inc. and Rohm & Haas Canada LP. which are covered by the
companys commitment to the Responsible Care initiative of the Chemistry Industry Association
of Canada. A description of the company in Canada and which operations are covered by this
report can be found in Appendix 1.
1b)
Responsible Care
Responsible Care is an initiative of the Chemistry Industry Association of Canada (CIAC) by
which the associations members and partners commit to be, and to be seen as, responsible
companies within Canadian society. It is based on an ethical approach to the safe and
environmentally sound management of chemicals an approach which started in Canada but
has since spread to over 50 countries around the world.
The Responsible Care Ethic:
We are committed to do the right thing and be seen to do the right thing.
We are guided towards environmental, societal, and economic sustainability by the following
principles:
We are stewards of our products and services during their life cycles in order to
protect people and the environment.
We are accountable to the public, who have the right to understand the risks and
benefits of what we do and to have their input heard.
We respect all people.
We work together to improve continuously.
We work for effective laws and standards, and will meet or exceed them in letter
and spirit.
We inspire others to commit themselves to the principles of Responsible Care.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 8 of 37
The ethic is supported in Canada by six codes of practice covering relations with the
communities where members facilities are located and also responsible management
throughout the product life cycle. Information on these codes of practice and related activities is
available from company personnel listed in Appendix 2 of this report, or via the CIAC web site
www.canadianchemistry.ca (click on the tab for Responsible Care).
1c)
1d)
Verification
A companys declaration that the expectations of Responsible Care are being met is an
important first step in the verification process, which leads to confirmation and recognition of
this by a team of industry and public representatives. Verification is conducted to strict
protocols, developed by the associations members and others including several critics of the
chemical industry and its operations. The first verification takes place when the company first
states that its performance meets the expected level (Responsible Care-in-Place). This
verification is designed to confirm, for the companys peers in CIAC and the public, the
existence of a companywide ethic and management systems which ensure that the principles
and codes of practice of Responsible Care are not only in place but are also practised and
continuously improved within the organization.
Subsequent verifications are also conducted using a different protocol, approximately every
three years after formal acceptance of the first verification, to ensure that the ethic and
management systems of Responsible Care are firmly rooted in all the companys operations.
This is known as re-verification.
Each verification is conducted by a team consisting of:
knowledgeable industry experts with experience in Responsible Care;
a representative of the public at large (usually with a public interest background and with
experience in Responsible Care gained from serving on the CIACs national advisory panel)
and
one or more representatives of the local communities where the companys facilities are
located.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 9 of 37
1d)
ii) Re-verification
Approximately every three years after team acceptance of Responsible Care-in-Place, the
CIAC schedules further verifications using a modified approach. The team is similar to that for
the original verification, with at least one team member from the previous verification but a
different leader.
In re-verification the team probes more deeply to examine how well the ethical basis of
Responsible Care is understood and adopted within the company, and also how effective are
the companys management systems in applying the ethical principles throughout the
companys operations. This involves not only whether the company intends to do the right
things, but also how it monitors activities and results and takes corrective action when
deviations occur (often referred to as the Plan-Do-Check-Act parts of the management
system).
For re-verification the company is given a more comprehensive list of documentation the team
will need to see. Part of this must be sent to the team so they can study it in advance. The
questioning process is also more open, in that the team does not have to cover every topic in
depth but can probe where they feel it is most relevant for that individual company, plus any
areas where the company itself would like feedback on its performance.
After studying the information the team meets with the company to plan the visit stage of the
verification, at which a schedule is agreed covering people the team wishes to interview in
depth during the subsequent visit stage of the verification process. Most of these will be
company personnel, but some will be representatives of organizations with which the company
has business relationships customers, transporters, etc. and of local communities where
plants, etc. are located.
The team examines how strongly the Responsible Care ethic appears to be part of the
companys way of doing business, including awareness of Responsible Care and its
implications among the companys employees. The examination then progresses into a broadranging review of the companys management systems for Responsible Care, with a special
investigation into certain topics highlighted by CIAC in the verification protocol.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 11 of 37
The team looks at how effectively the companys management systems ensure that
Responsible Care principles and code obligations continue to be met, as established in the
initial Responsible Care-in-place verification. In subsequent verifications, however, the
questioning process also considers how the company tracks and improves its performance
regarding these obligations, including how performance measures are established and targets
met (what is measured, what are the goals and how are they achieved). Actions taken on
concerns, suggestions and recommendations raised in the last verification report are
examined, as are significant issues and incidents that have arisen since the previous
verification. The team then looks at how the company shared the results of this verification with
the local community, and examines how robust the ongoing process of community dialogue
appears to be and how issues and concerns are being identified and addressed.
The highlighted topics of special focus are ones where the feedback from the verification
process and from the association's members has suggested the value of a closer examination
of the general membership performance and comparison with the intent of the codes of
practice. This does not necessarily imply that any given company is not performing well, but
reveals the range of performance and identifies both cases where some improvement is
recommended and also examples from which others can learn.
Most recent previous Responsible Care Re-verifications
Company name at time:
Dow Chemical Canada Inc. and Dow AgroSciences Canada Inc.
Date of verification (visit):
March 19-23, 2007
Locations visited:
Fort Saskatchewan and Sturgeon County, Alberta
Team follow-up needed:
No
Date of final sign-off:
November 6, 2007
Company name at time:
Date of verification (visit):
Locations visited:
Team follow-up needed:
Date of final sign-off:
The report below presents the findings of the team from this re-verification of Dow Chemical
Canada ULC, Dow AgroSciences Canada Inc. and Rohm & Haas Canada LP. The report does
not address all aspects of Responsible Care, as this was covered by the report of the original
Responsible Care-in-Place verification. Instead, it focuses more on the items where the team
felt there was an opportunity or need for improvement, plus any improvements or practices
which are so significant that they should be shared with other CIAC members and partners as
possible examples.
For more context or explanation of any of the items below, please get in touch with the
company Co-ordinator or the contact at the company from whom you accessed this report.
In the following sections of this report, findings requiring action are shown in bold face,
Opportunities for Improvement (recommended but not considered mandatory) are shown in
italics, while Best Practices and Extra Miles are shown underlined).
2.
2a)
Throughout the interview process the team checked for evidence that the Responsible Care
ethic was visible and at work in the company, guiding the companys judgement, decisions and
actions.
FINDINGS
Overview:
Consistent with what was concluded during previous re-verifications, the Re-verification team
found that the Responsible Care ethic is well understood, is integrated into all aspects of the
organization, guides actions and decisions throughout and is considered as a way of doing
business for all Dow entities and sites in Canada. The Executive Contact articulated significant
support for Responsible Care and is personally pursuing an initiative to have Responsible Care
introduced into the engineering curriculum of selected leading Canadian Universities. As part of
the CIAC annual Responsible Care attestation process, rather than just base this on what he is
told, the Executive Contact has requested to see all audit summaries and plans to participate in
some audits. The company is actively engaged with its key stakeholders, and sees
Responsible Care as being that which must be done every day to maintain its licence to
operate with those stakeholders. It has demonstrated itself very capable of identifying
deficiencies through its management systems, processes, and performance indicators, and
demonstrates continuous improvement consistent with the expectations of the companys
stakeholders, employees, peers, and governments.
A new Responsible Care Ethic and Principles for Sustainability have recently been developed
by the CIAC. A fact finding questionnaire in this regard has been completed by the company.
This is included as Appendix 3 to this report.
Best Practice:
The CIAC Executive Contact is commended for his initiative to have Responsible Care
introduced into the engineering curriculum at Canadian Universities which he intends to pursue
until programs are established at the those identified for initial implementation.
2b)
Act
There must be such management systems that covers both for the overall management of the
company and for each code element. This section 2.3 covers the teams findings with respect
to this overall management system, and section 3 below covers the specific code elements that
were reviewed in the re-verification.
FINDINGS
Overview:
The company utilizes an integrated management system referred to as the Operating Discipline
Management System (ODMS). It is based upon the plan-do-check-act continual performance
improvement cycle, and integrates the companys management systems for manufacturing,
quality, environment, health, and safety. The system provides access to policies, requirements,
processes, best practices and procedures.
Third party internal audits (i.e., environment, health and safety, product stewardship, and
reactive chemical / process hazard analysis) are conducted on a three year frequency. Selfassessments are conducted yearly for some of the Operating Discipline Management System
elements, while others are conducted on a three year frequency. Action items arising from the
above audits and reviews are tracked to completion through a process referred to as the Event
& Action Tool.
Dow follows a procedure that documents the reviews that take place annually before the
attestation to CIAC by the Dow Canada President. The Canadian Responsible Care
Leadership team (CRCLT) has a delegated responsibility from the Executive Contact to monitor
Responsible Care performance in Canada. This procedure involves the CRCLT and the code
coordinators within Dow, Dow AgroSciences and now Rohm and Haas Canada. Quarterly the
CRCLT meets to review Responsible Care and reports to the Canadian Board of Directors
which includes the Presidents of both Dow and Dow AgroSciences and the senior Rohm and
Haas leader.
Management system gap assessments have been completed against each of the six existing
Responsible Care Codes of Practice, and a first pass gap assessment is being conducted
against three new codes, which have recently been developed to replace the original six.
Objectives are managed through a process referred to as the Managing Implementation Plan,
which includes specific environment, health and safety goals.
The Dow AgroSciences Quality, Environmental, Health, Safety, Technology (QuEHST) Review
Program was developed to verify and document Dow AgroSciences compliance with applicable
government standards and company policies, guidelines, and requirements, which include
Operating Discipline, Responsible Care and applicable industry standards.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 14 of 37
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 15 of 37
ii) The companys Event and Action Tool which tracks actions arising from various work
processes (e.g., incident investigations, audits, etc.) with automated follow-up to confirm
that tasks are completed correctly and as scheduled by those assigned to same.
iii) The Saskatoon facility approach, whereby individuals from within the organization are
assigned as EH&S focal points, which increases involvement in EH&S delivery and buy in.
2c)
2d)
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 16 of 37
Review processes exist at the local, functional and corporate levels, and manufacturing
leadership review all major incidents and monitor for overdue corrective actions.
All reportable and near miss incidents are recorded in a computer database. These incidents
include those related to personnel safety, loss of primary containment, process safety,
government reportable, motor vehicle, neighbour complaint, transportation safety, customer /
terminal / distributor facility, and security.
Opportunity for Improvement:
i) Establish a process to ensure that the closure on action items for the Event & Action Tool
address the root causes of the issues, not just the surface fix.
2e)
Performance Measures
The check step of a management system is the part that shows the effectiveness of the
system, and a key question is: What does the company check as its indicator of
performance? For a few items emissions & wastes, occupational safety & health, incidents
related to transportation or process operations CIAC specifies measures for reporting under
Responsible Care. Most other areas are left to the discretion of each member or partner. The
team was asked to review and comment on the measures used by the company to track and
improve performance. Some of these are covered under specific sections below, but general
comments are given here.
FINDINGS
Overview:
After completion of the EH&S 2005 Goals, Dow set new goals to elevate performance to the
next level with the 2015 Sustainability Goals which were introduced in early 2006. These goals
track a range of metrics from environmental emissions and impacts, resource productivity
measures such as production energy intensity, to monitoring for personnel and process safety
performance. The company also reports its emissions, wastes, transportation incidents,
occupational injuries and illness, and process-related incident data into the CIAC membership
database.
In addition to the above, community concerns are tracked and there are on-going efforts to
minimize the impact of company operations on local communities.
Opportunities for Improvement:
i) Consider raising the profile of the companys current leading performance indicators (i.e.,
activities with a proactive preventive focus) by sharing key results with employees and
leadership, similar to what is done at Prentiss.
Best Practices:
i) The public publishing of Dows Corporate Sustainability Goals.
ii) The linking of performance targets to individual pay increases at all organizational levels at
Dow Chemical Alberta sites.
iii) The comprehensive list of leading performance indicators.
3.
3a)
The team looked at how the hazards and risks from potential episodic ('sudden') incidents are
identified and controlled at the companys sites, including awareness and understanding of the
methods used for assessment and the techniques for hazard control, and how these are
applied and kept current. This includes how the companys sites rank based on the CIAC High
Inventory Site Assessment Tool whether they meet criteria for the essential level of PSM,
and how the company has assessed the value of aspects beyond the essential level.
FINDINGS
Overview:
To address aspects of hazard control the company has applied a process referred to as Layers
of Protection Analysis. This is a structured approach to the identification of hazards, and
provides specific focus as to the actions required to reduce or eliminate those hazards.
There is a comprehensive process safety program in place, which addresses risk assessment,
hazard reviews, reactive chemicals reviews, equipment integrity, loss prevention, regulatory
requirements, hazards awareness, community awareness and emergency response,
management of change, incident and near miss tracking, and auditing. Worst Case and
Emergency Planning Case scenarios are periodically evaluated and are revised as standards
or models change. Process Risk Assessments are conducted on a three to five year cycle
depending on the risks present at the individual site. Trained personnel carry out the reviews.
Both Dow Chemical Alberta sites have attained the second level (Enhanced ) of three possible
levels of process safety program implementation as defined by the CIAC High Inventory Site
Assessment (HISAT) Tool. The Dow AgroSciences Sturgeon County, Alberta site planned to
achieve the Enhanced level by January 2011 while the Rohm & Haas West Hill, Ontario and
the Dow Varennes sites were at the first (Essential) level.
Opportunities for Improvement:
i) Establish a plan detailing how all company sites might move to the Enhanced and
Excellent levels of process safety, according to the CIAC High Inventory Site Assessment
(HISAT) Tool. Document the rationale where any decision has been made not to move to
higher levels.
ii) Establish a process to ensure that all operating procedures at the Prentiss Site are updated
according to schedule. A number were noted as being beyond their review target date.
iii) Complete current plans to clearly document the safe operating envelope for the Prentiss
LP7 facility by the June, 2011 completion target.
iv) Complete current plans at the Rohm & Haas West Hill site to complete a layers of
protection analysis (LOPA) by the current targeted completion in 2011
Best Practices:
i) The entire documented process safety management system, which is comprehensive and
completely addresses state of the art aspects of process safety.
ii) The Layers of Protection Analysis (LOPA) program which identifies site-specific process
hazards and identifies actions to mitigate those hazards.
iii) The detailed process safety near miss reporting which requires that such items as all safety
valve openings are reported and formally investigated.
3b)
The team looked at how the company had identified and assessed the security vulnerability of
its sites, and how it had selected and implemented countermeasures to address security
concerns. The team also examined how the company assesses the full range of risks its site
operations may present to their communities, together with the process for liaison with local
emergency officials at each site, and for developing, coordinating and testing site emergency
plans with those of the community.
FINDINGS
Overview:
Security vulnerability assessments were completed in 2007 and follow-up actions have been
addressed and documented. There is also a security policy in place for all sites.
Site personnel access is controlled using a card access system, and vehicle access is limited to
designated gates. Vehicle and trunk inspections are done at random. Information Technology
security includes a firewall and computers are expected to be locked when not in use.
Computers are password protected and internet traffic is monitored.
At the Fort Saskatchewan facility, a process referred to as Scenarios of Significance has
been established. This identifies potential incident scenarios and uses of the information
obtained to assist in preparing for potential emergencies. There is a corporate crisis
management plan in place and both Dow Alberta sites have established emergency response
plans, which include all of the activities necessary to resource, prepare, plan and respond to
anticipated potential site and community impact emergencies. This includes on and off-site
training for emergency responders. There is a defined process in place for debriefing
emergency incidents. This includes a follow-up process to ensure that all action items have
been addressed.
The Fort Saskatchewan site is a member of an organization referred to as the Northeast
Region Community Awareness Emergency Response group which is a regional mutual aid
emergency response association established to coordinate the sharing of emergency response
resources, personnel and services available in the region. The organization was formed to
develop and improve upon the regions emergency response capabilities. There is an
information update telephone line to the site allowing residents to call if they have questions
about industrial site activities such as loud noises, flaring, traffic levels or unusual smells. There
is also a call out system that Northeast Region Community Awareness Emergency Response
members can use to provide residents with information about more serious (non-emergency)
incidents. The call out system supports the municipal and provincial notification systems used
to convey emergency and safety information to residents.
The Prentiss site is a member of the Lacombe County Mutual Aid Organization. This
organization provides additional resources in a coordinated response to deal with all natural
and industrial emergencies. The organization regularly practices emergency response, together
with all its members, to ensure the mutual system is effective. The site maintains a community
update telephone line to the site, allowing residents to call if they have questions about site
activities. A call out call out system is also available, in the event of emergencies that require
neighbours to take action. Worst Case and Emergency Planning Case scenarios are
periodically evaluated and are revised as standards or models change. Regular drills are
carried out for on site and community emergency scenarios.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 19 of 37
The West Hill site is a founding and active member of the Toronto East CAER group which is
used to prepare area companies for emergencies and mutual aid. Each year, the Toronto East
CAER group organizes a full scale emergency response test with the West Hill site included in
the test schedule. The local community is advised of exercise results at community meetings
held each Spring. Fire Department crews visit the site annually and the Fire Department has
reviewed and commented on the site emergency response plan. Site responders are trained
using defined response scenarios addressing identified risk categories.
The Dow AgroSciences Sturgeon County and Saskatoon sites as well as the Dow Varennes
site have limited emergency response capabilities and depend on their local Fire Departments
for all but very minor response scenarios.
FINDING REQUIRING ACTION:
i) It is a finding requiring action that a management system be in place to ensure that
near industrial neighbour S.C. Johnson and local emergency responders are notified,
and periodically updated, regarding risks presented by the Varennes site and that
joint site emergency response exercises take place.
Opportunities for Improvement:
i) Consider inserting a requirement into supplied service contracts to carry out background
checks on all contract employees, in key positions identified by Dow, coming to company
facilities.
ii) Consider implementing, at all manufacturing sites, the Scenarios of Significance process
in place at the Fort Saskatchewan facility, to identify potential incident scenarios for use in
emergency preparedness event planning.
iii) In collaboration with local authorities and in consultation with the companys Community
Advisory Panels, at all sites, establish a process to test, through to its conclusion, the
community emergency call system to potentially impacted neighbours (i.e., not just a test of
the call system technology but to check that people have actually been contacted and
advised what to do).
iv) In collaboration with the local authorities and in consultation with those potentially affected,
check the effectiveness of the emergency notification process for people working in fields
surrounding the Prentiss site.
v) Complete the planned company crisis management plan exercise by the scheduled date in
2011.
vi) Build severe weather complications into site emergency exercise scenarios (e.g., people
exposures to heat or cold, response equipment breakdown/unavailable due to freezing/bad
road conditions, etc.).
vii) The Varennes site are encouraged to have their updated site impact assessments
externally validated and then communicated to local responders and the impacted
community.
viii) The Varennes site is encouraged to validate that nearby loaded rail cars would not be
impacted by a significant Styrofoam fire incident.
ix) Periodically meet with local hospital emergency staff for information sharing on potential
injuries and exposures to employees, the extent of support possibly being required during
emergency events, emergency communications etc.
Note: Some activity has taken place on such information sharing in Fort
Saskatchewan.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 20 of 37
Best Practices:
i) The Scenarios of Significance process in place at the Fort Saskatchewan facility, which
identifies potential incident scenarios and use of this information for emergency
preparedness event planning.
3c)
Product Stewardship
For this aspect of Responsible Care, the team examined the companys processes for
assessing the exposures of people to its products over their life cycles, assessing the potential
health implications of these exposures, communicating information to those potentially affected
and taking action to prevent health impacts; ensuring that their products are not used by
terrorists, the illegal drug industry or others who might use them for illegal purposes; and
ensuring that suppliers of chemicals are meeting the intent of Responsible Care.
FINDINGS
Overview:
Dow has a corporate Product Stewardship Management Standard, which was developed to
meet the best in class from various regions in which the global company operates. The Dow
process for assessing exposures of people to substances in manufacturing processes or its
products over their life cycles involves conducting both a hazard assessment and exposure
assessment which, when combined, results in a substance/product risk assessment. Dow
utilizes EH&S expertise, Subject Matter Experts (SME's) e.g. toxicologists, environmental fate
specialists, environmental risk assessment specialists, etc. to assist in the hazard assessment
of products and to define potential gaps in product information necessary to define product
hazard. In addition, various means of determining potential product exposure are used,
including direct monitoring, exposure modeling, field-testing, sharing among industry consortia
and academia, and access to information from down-stream partners and direct customers.
Dow utilizes Business Health Teams to conduct reviews of the product hazard and exposure
information and when appropriate takes responsible action to minimize risk. Finally, various
leveraged EH&S expertise and business resources are utilized to conduct product EH&S risk
reviews, create and communicate product hazard documentation, document product risk
assessments and assist with public access to this information. Dow also participates in various
assessment programs; in Canada, the Priority Substances List (PSL) assessments and
Chemicals Management Plan Industry Challenge; outside Canada, the Global Product Strategy
and the High Production Volume initiatives for product hazard determination leading to risk
assessment. The results of these risk assessments and others are then incorporated to assist
in managing the risks associated with Dow products. For more information, see the Product
Safety Assessments at http://www.dow.com/productsafety/assess/index.htm
Opportunities for Improvement:
i) Establish organizational links in Canada to the supply chain services provided from the
United States to ensure that CIAC Responsible Care aspects are appropriately addressed
in all activities (e.g., transportation, warehousing, distributors, etc.).
Best Practices:
i) Use of a Sustainable Chemistry Index to help measure progress (with a defined target) in
improving product portfolios to become more sustainable.
ii) While not by Dow in Canada, the decision taken to manufacture chlorine in California rather
than doing so in the Gulf of Mexico area and shipping it to California. An example of a
positive contribution to the Dow Chemical 2015 goal of reducing shipment tonne miles by
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 21 of 37
50%.
3d)
Environmental Management
In addition to examining in general the companys performance in reducing its environmental
footprint, the team looked specifically at the company's performance history and 5-year
projections regarding greenhouse gas emissions. This included actions both taken and
planned, and whether through direct reduction of emissions or indirect reduction through such
measures as improved efficiency in use of energy or materials, changes in technology, etc. For
fact-finding purposes only, to assist CIAC in developing recommendations for addressing
growing concerns over water consumption, the team also reviewed any actions taken by the
company to identify and reduce its usage of water.
FINDINGS
Overview:
There is a clear focus evident on reducing the impact of company operations on the
environment. Corporately, Dows commitment is to, by 2015, reduce company-wide emissions
of volatile organic compounds by 30%, NOX by 30% and priority compounds by 30% from
2005 levels. Corporately, the commitment is to re-use 300 million pounds of by-products as raw
materials, instead of disposing as waste. Dow Canadas commitments are aligned with this
global expectation. Various examples of improvements were provided to the re-verification
team during our site visits, evidencing that a strong commitment towards environmental
excellence exists throughout the company. Examples include the following:
At the Varennes facility, conversion to zero ozone-depleting, no-VOC (volatile organic
compound), foaming agent technology in the manufacturing of Styrofoam Insulation.
The polyethylene plants in Prentiss and Fort Saskatchewan manufacture specialized plastic
resulting in thinner packaging, which reduces waste to landfill and conserves the
hydrocarbon and energy resources used in manufacturing the product.
The Prentiss Dow Chemical site is moving towards fugitive emissions surveys being
performed semi-annually from the current annual schedule.
Dow AgroSciences 100% conversion to recycled materials for construction of its corrugated
boxes as soon as the existing box inventory is used
Opportunities for Improvement:
i) At the Varennes site, complete their project to upgrade the shavings extraction and filtration
process to a bag filter system by the targeted completion of Q1, 2012. This will not only
reduce shavings emissions but also reduce operating area noise level exposures.
ii) An improvement opportunity is to ensure that one of the planned semi-annual fugitive
emission surveys at Dow Chemical sites be performed shortly after start-ups following
maintenance shutdowns.
Best Practice:
i) The company requirement to internally report, and investigate these to prevent recurrence,
all spills over 50 kilograms even if non-hazardous or within secondary containment, this
helps to create a zero spills attitude among all personnel.
ii) Significant focus on greenhouse gas emissions and water usage management.
3e)
understand the essence of Responsible Care and its relevance to their job activities and
decisions.
FINDINGS
Overview:
There was a general awareness of Responsible Care among employees and those who were
contacted were able to relate the essence of the ethic to their everyday work.
Numerous communication tools are used to promote Responsible Care awareness among
employees. This includes the companys Managing Implementation Plan, news line stories,
web sites, communication meeting presentations, and conference room posters. Public
communication is done via the sites Community Advisory Panels, etc. Since 2007, two surveys
of employee knowledge of Responsible Care have been completed, with the latest one
completed in September 2010.
The Varennes site does not currently have a formalized Responsible Care training program for
new or existing employees.
Opportunities for Improvement:
i) Upgrade the Prentiss site visitor orientation video to promote Responsible Care similar to
that which is understood to exist in the Fort Saskatchewan site video.
ii) Enhance Responsible Care visibility both inside and outside the company by adding the
logo and attendant wording to documentation (e.g., business cards, letterhead,
presentation templates, supplier and sales documentation, etc.).
iii) To enhance awareness of Responsible Care, establish a specific (by name) orientation
session for new employees and contractors, and an update for existing employees, that
reviews the Ethic, Principles and Codes of Practice, how the company complies with these
requirements through its ODMS etc.
Note: The model developed by Dows overall Responsible Care Coordinator during the reverification visits could serve as an excellent tool for widespread use in this regard.
3f)
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 23 of 37
The health and safety hazard identification process includes job safety analysis, exposure
assessments, health assessments, workplace hazardous materials information, material safety
data, and hazard communications, indoctrination, and training.
The health assessment program defines for employees, based on their potential for chemical,
physical or biological assessment exposure and their age, the baseline medical assessment
and the health surveillance and screening examinations required.
In addition, to prevent and control health and safety hazards at the job/task level, written
operational controls and task procedures are implemented for activities such as confined space
entry, electrical work, hot work, hydro blasting and pressure washing, lock-out and isolation of
energy sources.
New health risks recently discovered by medical sciences and/or as a result of studies
conducted by medical sciences are communicated to employees as appropriate.
In addition, there is a routine workplace safety observation program in place in Alberta
Operations whereby complete jobs are audited in the field for safety behaviours etc. This
program is referred to as Change Maker Audit.
Opportunities for Improvement:
i) At the Prentiss site, consider checking to ensure that contractor employees feel free to
report unsafe situations within their own companies.
(Note: During an informal discussion, one contract individual indicated some difficulty
with this.)
ii) With 50% of site business incidents currently involving fork lift trucks, the Varennes site are
encouraged to complete their planned projects to double the size of their finished product
storage area and improve storage and loading area lighting by their Q3,2011 completion
target.
iii) The Varennes site is encouraged to improve their Industrial Hygiene monitoring system as
detailed in the November, 2010 corporate audit.
Best Practices:
i) The pre-job task analysis process which includes routine and non-routine work related to
process operations, maintenance, laboratory activities, office work, driving, and travel.
ii) The Change Maker Audit program whereby entire audits of jobs in progress are undertaken
by trained staff on a scheduled basis.
iii) The use of contracted qualified safety professionals to act as safety watches during
turnarounds, as opposed to the traditional approach of hiring general contract employees
and providing them with the minimum basic training to carry out this work.
3g)
and the meeting was advertised in local newspapers. The next communication of worst-case
scenarios is planned for 2011.
In Fort Saskatchewan, the last community review of the worst-case scenario was covered in
2006. Since the Fort Saskatchewan site has engaged its Community Advisory Panel in a
variety of ways with respect to risk communication. In 2009, the Community Advisory Panel
received a presentation on a significant site release scenario and activation of all emergency
measures. In 2011, there are plans to work with the broader industry group in Fort
Saskatchewan, through an organization referred to as the Northeast Region Community
Awareness and Emergency Response group, to update the community on worst-case
scenarios through an open house.
The Rohm & Haas site uses their annual spring and fall open houses, their annual newsletter
to neighbours and their neighbour visiting program to communicate site risks.
In April 2007, the Varennes site conducted a public meeting along with other industrial risks
generators to discuss its worst case and emergency planning scenarios. All Varennes citizens
were invited to a town hall meeting held at the local High School. Local officials including the
mayor, Fire Chief, Chief Medical Officer, Environment Officials, etc, conducted the meeting.
Each company worst-case scenarios, including toxic and or flammable materials were
reviewed. A DVD has been distributed to all Varennes houses to explain what the emergencies
could be, how the public would be notified, what actions are to be taken by the public, how they
could follow progress on the event and how they would be notified when the emergency is
over.
FINDING REQUIRING ACTION:
i) At the Sturgeon County facility establish an active (e.g. face to face) program to
advise neighbours, who may be impacted by a site incident, as to the potential nature
of the incident and what to do in an emergency.
Opportunities for Improvement:
i) At the next community site operations risk communication at the Fort Saskatchewan facility,
scheduled for 2011, ensure that, as well as general communications, direct contact is made
with all Dow neighbours who may be impacted, with information on the nature of the
potential impact and what to do in an emergency.
ii) In future community site risk communications include a test of knowledge regarding shelter
in place.
iii) The Varennes site are encouraged to communicate their updated site risk information to
potentially impacted neighbours upon completion of the external risk assessment validation
which was to commence shortly after the re-verification site visit.
Best Practice
i) The West Hill site process to, at defined intervals, personally contact neighbours who could
be impacted by a site incident, advising them as to site risks and what to do in an
emergency.
3h)
methods. They looked at the effectiveness of the management system in ensuring the
company is planning, implementing, evaluating and continuously improving its relationship with
the community.
FINDINGS
Overview:
There is a documented management system in place for community dialogue that addresses
the requirements for community outreach.
The Prentiss, Fort Saskatchewan, and West Hill sites participate with Community Advisory
Panels, which have proven to be very effective in providing appropriate dialogue between the
company and the communities in which it operates. These locations also use a variety of tools
to communicate with its community. This includes open houses, exhibitions, and tours. News
releases and briefings are provided to the media as required, and correspondence,
newsletters, e-mail, and publications are used to distribute information to target audiences.
At Varennes, the prime local community contact is via meetings with the local industrial
association (AIV), which includes Industry and Community representatives. Meetings with site
neighbours were held in June and September 2008 and in June 2009. However, none were
held between then and the latest in November 2010, reportedly due to extensive site
renovations taking place during that time.
Opportunities for Improvement:
i) Consider including representatives of the companys Community Advisory Panels in annual
Responsible Care related management system reviews.
ii) Consider providing a simplified overview of the Layers of Protection Analysis program to
Community Advisory Panels.
iii) The CIAC Executive Contact should consider meeting face to face with the CAPs to
introduce himself and engage in dialogue.
iv) Look into the possibility of addressing community issues that may be common to the
Prentiss facility and the nearby NOVA Chemicals/Ineos facility. One option would be
through joint Community Advisor Panel sessions.
v) At West Hill CAP meetings, include community emergency notification as an agenda topic
at prescribed intervals.
vi) Establish a formal process for ongoing communications with near neighbours at the
Sturgeon County and Varennes sites.
Best Practices:
i) The membership, dialogue, level of engagement and trust within the Community Advisory
Panels in place at the Prentiss, Fort Saskatchewan and West Hill facilities.
3i)
Social Responsibility/Sustainability
In this area the team was not looking for evidence that the company's performance met certain
expectations, but rather for information on ways the company has provided benefits to, and
worked to understand and further the social aspirations of, its local communities and broader
society beyond the boundaries of EH&S performance. Aspects considered include working
with schools, progressive employee programs, support for charitable work, policies for
investments and operations abroad, workplace diversity, corporate ethics policies, policies for
suppliers in social responsibility, etc.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 26 of 37
Social Responsibility
FINDINGS
Overview:
The company has a strong commitment to the community and contributes though monetary
funding and volunteering. While focusing on community need and sustainability, the
companys community investment program has benefited youth, education and support of local
environmental initiatives. Employees can approach the company to support their own local
community interests.
The company believes that good corporate citizenship includes being a responsible operator,
an employer of choice and enhancing their communities. There is a clearly defined Code of
Business Conduct document in place which addresses company values, respect for
employees, protection of the environment, assets and reputation, market place and financial
integrity, and reporting.
Examples of Dows community outreach activities in the areas of Social, Economic Prosperity
and Environmental Stewardship include:
Donation of surplus office equipment and emergency equipment to support local community
organizations
The donation of two fully functional fire trucks to Canadian Aid for Fire Services Abroad
(CAFSA). The trucks are stocked with Personal Protective Equipment that will protect
firefighters in Chile.
In March 2008, the Prentiss site provided an emergency vehicle equipped with motor
vehicle rescue gear to the Sto:Lo people, a First Nations band on Seabird Island in British
Columbia. Additionally, Dow donated six full firefighter suits to the country of Mexico.
Major contributor to the Dow Centennial Centre in Fort Saskatchewan
Hands-On-Science Partnerships
Ducks Unlimited/Dow Canada 3 year Partnership for the expansion and improvement of
wetlands
Ontario Regional contributions (e.g. National Engineering Week, Block Parent Program,
National Robotics Competition; Engineering Week, etc.)
Sarnia River Remediation - 3 year project to remove the historical contaminants to the St.
Clair River opposite the Dow Sarnia Site
Red Deer River Clean Up sponsorship and participation
Support for Ellis Bird Farm at Prentiss
Fort Saskatchewan Urban Forest Tree Planting
Habitat for Humanity
Sustainability
In this area, the team was not looking for evidence that the company's performance met certain
expectations, but rather for information related to company objectives and initiatives in this
topic area. This information is included as Attachment 3 of this report.
Team Observations
Dow has made significant, publicly stated, 2015 Sustainability Goals in each of the following
seven areas:
i) Local Protection of Human Health and the Environment
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 27 of 37
ii)
iii)
iv)
v)
vi)
vii)
The team observed organizational commitment and progress towards achieving these goals
during this re-verification
Opportunities for Improvement:
i) Promote the Dow Sustainability Model in Canada under the banner of Responsible Care
given that CIAC now describes Responsible Care in terms of its Ethic and also Principles of
Sustainability.
Best Practices:
i) Dows appreciation expressed with sensitivity to the Sarnia community following the closure
of their significant operating facilities, by involving community representatives in the
selection of a legacy project, the Youth Centre, as well as in donating their existing
wetlands venture to the St. Clair Region Conservation Authority.
ii) Dow AgroSciences R & D focus on Sustainability via developing agricultural seeds and
traits which will reduce insecticide, nutrient and water usage while yielding crops at
increased productivity, which are better for human health.
Extra Mile:
i) Dows publicly stated stretch 2015 Sustainability commitments and Dow Canadas
organizational alignment and commitment towards their achievement.
3j)
3k)
Transportation Security
The team looked at how the company assesses the risk of deliberate misuse of products or raw
materials in transit and provides protection against such risks.
FINDINGS
Overview:
In recent years, significant efforts have taken place in the area of transportation security, and
there is a transportation security plan in place.
Dow uses multiple modes of transportation including marine, pipeline, rail, and road
transportation. The majority of Dow Chemical shipments from are by railroad, including both
main line and short haul railroads. The main railroads are self-assessed through a Dow
questionnaire. The company does not assess short haul rail lines. Short line railways in
Canada are assessed and monitored through a Railway Association of Canada process Road
carriers are assessed as detailed in section 3l) of this report below. Pipelines can be either
jointly owned and operated or simply passing through company property. The company does
assess the pipeline security management systems and auditing of the non-company portions
by its pipeline suppliers or users to confirm that these lines are maintained to Dows
requirements.
Although the vast majority of companys products are considered non hazardous in Canada,
several security measures have been put in place, such as sealing of every loaded rail car and
sealing of every empty car upon return.
3l)
Carrier Selection
The team looked at the companys process for establishing criteria for the selection of road,
rail, marine, pipeline and air carriers, and for ongoing assessment of those carriers against
those criteria.
FINDINGS
Overview:
CIACs contract service provider, QRC & Associates, formally evaluates motor carriers selected
for transporting final products from the Rohm and Haas and Dow AgroSciences sites using the
CCPA approved Motor Carrier Evaluation protocol. US based motor carriers are selected and
approved by a corporate function in the USA. Dow Canada facilities use only corporate
approved carriers. The company has a well-defined carrier selection and qualification process,
which includes review and monitoring of environment, health and safety performance prior to
and during the execution of carrier contracts. However, at the Varennes site, carriers picking up
product were reportedly selected by a load broker contracted by Dow in the USA with
equipment arriving on site being inconsistent as to age and quality.
Opportunities for Improvement:
i) Upgrade the customer pick up equipment checklist at the Varennes site to include
roadworthiness items.
ii) Ensure that Dows corporate carrier selection process includes formal standards to be
applied to load brokers.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 29 of 37
3m)
TransCAER Outreach
TransCAER is the CIAC program for Transportation Community Awareness and Emergency
Response. It involves the companys approach to preventing transportation incidents, its
transportation emergency response plan, and also outreach to communities through which
chemicals are transported. Regional TransCAER committees formed from the members and
partners in each region decide company responsibilities. The team looked at how the company
has participated in TransCAER outreach in each region where it has facilities, and how
effectively the Responsible Care ethic drives the building of relationships with targeted
stakeholder groups.
FINDINGS
Overview:
The company is represented in TransCAER community meetings, and is actively involved in all
local TransCAER events. A Dow Canada representative co-chairs the Prairie Regional
TransCAER Committee. The Rohm & Haas site actively participates in Toronto TransCAER
group activities and the Varennes site is similarly involved with the Quebec Regional
TransCAER Committee.
3n)
4.
CONCLUSION
As a result of the various site visits, documentation reviews, interviews with company
personnel, and meetings with local Community Advisory Panels, the re-verification team is
satisfied that the companys decision-making and actions are strongly underpinned by the
Responsible Care ethic, and that the overall management system is self-healing (i.e., based on
a process of continual performance improvement, and identification and timely correction of
deficiencies). This was also demonstrated by the clear commitment of company personnel to
do the right thing and do it well.
5.
COMPANY COMMENTS
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 30 of 37
Dow Canada was a key supporter of the original Responsible Care development in 1985 and
remains committed to the ethic and principles of Responsible Care 26 years later. Our
company has changed tremendously but our commitment remains the same. The Reverification process adds value to Dow Leadership by identifying opportunities that will improve
Dow Canadas Responsible Care system and performance. We also appreciate the many
Best Practices the Re-verification Team identified and the Extra Mile noted.
The Re-verification Teams, including the three community representatives, were professional
and thorough in their evaluation of how the Dow Canada family of companies meets the
Responsible Care ethic. We appreciate the work of the many employees of Dow, Dow
AgroSciences, and Rohm and Haas across Canada not only for their participation in the Reverification but in living the Responsible Care ethic every day. Our Re-verification for 2010 sets
the stage for the transition to the new Responsible Care Codes.
Elaine Wasylenchuk,
EH&S Regulatory Manager, Alberta Operations
Dow Chemical Canada ULC
March 28, 2011
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 31 of 37
APPENDIX 1
COMPANY DESCRIPTION & CHANGES
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 32 of 37
Dow AgroSciences also acquired the assets of Hyland Seeds in early 2010, a division of
Thompsons Limited of Blenheim, Ontario. Hyland Seeds was not a member of the CIAC and is
currently implementing Dow Systems and Responsible Care as it becomes integrated into Dow
AgroSciences.
In November 2007, Dow sold the West Coast Distribution Centre in Vancouver. Plant closures
have also significantly changed the makeup of Dow in Canada. Facilities at Weston, Sarnia,
and London, Ontario were closed and divested. Parts of the Fort Saskatchewan site are closed
and have been demolished or are undergoing demolition (Chlor-Alkali, EDC Vinyl, and Foam).
The current Dow Canada is made up of the following facilities:
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 33 of 37
APPENDIX 2:
TEAM AND CONTACTS
1.
Representing
Industry (team leader)*
Industry*-Varennes Excl.
Industry Varennes Only
Public at Large-Varennes site visit
excluded*
Sandra Badry
Area Resident
Prentiss Community
Ronald Taylor
Area Resident
West Hill Community
Jean-Paul Morin
Area Resident
Varennes Community
Team members assigned by CIAC are shown by an asterisk (*).
2.
Affiliation
Consultant
Consultant
Consultant
General Public
Name
Dena Hutchison
Colin Allison
Stephanie Kozey
James Brown
Marcella deJong
Jean-Yves Vanier
Brian Mullen
Chris Thompson
Chris Vasilopolous
Garry Leischner
Joe Deutscher
Shawna Bruce
Ralph Smeding
Mike Buczkowski
Chris Pohl
Edward van Delten
Suresh Prabhakaran
Kimberly Steckler
Sherry Gorde
Rejeanne Cool
Ian Parkin
Normand Mercier
Roger Simard
Louis Ramsay
Joe Sabbagh
3.
Position
MPWPL / Learning Ldr. / HRD
P1 Activity Coordinator & Environmental EH&S Delivery Tech
Prentiss
Lab Team Prentiss
Climate Change Regulatory Affairs Specialist
Regulatory Affairs Specialist, Alberta Operations
Site Logistics Leader Alberta Operations
Dow WCO Transportation & Distribution Code Coordinator
Zone Outplant Specialist- Site Logistics Fort Saskatchewan
DAS Logistics Specialist, Transportation & Distribution Code
Coordinator
Dow WCO TransCARE Coordinator
Site Operations Director Alberta Operations
Public Affairs Leader Dow Canada
Process Safety Leader, Dow Canada
Run Plant Engineer/Production Engineer LP7 Prentiss
Loading Technical Advisor- Prentiss
Emergency Services & Security Technical Leader Fort
Saskatchewan Site
DAS R&D Saskatoon Site Leader Via teleconference
DAS Saskatoon Lab EHS Via teleconference
DAS Saskatoon Research Biologist Via teleconference
ME Global Responsible Care and Quality Leader
Varennes Production Leader
EH&S Delivery Technician Varennes
Environmental Coordinator Varennes
Gel Line Engineer Varennes
Finishing Line Engineer Varennes
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 35 of 37
APPENDIX 3
In 1995, the Dow Chemical Company set important goals to improve its environment, health
and safety performance and we were recognized for their achievements. In 2006, Dow set the
bar even higher with the introduction of a more ambitious, next-generation set of goals the
2015 Sustainability Goals. Their efforts will focus on strengthening their relationships within the
communities where they operate, continuing to improve their product stewardship and
innovation to solve some of the worlds most pressing problems, and to reduce their global
footprint. As a part of the companys 2015 Sustainability Goals, the people at Dow are
committed to using resources more efficiently, providing value to their customers and
stakeholders, delivering solutions for customer needs and enhancing the quality of life of
current and future generations. Dow, DAS, and Rohm and Haas globally and in Canada have
corporate alignment with the 2015 goals, with different emphases depending on operation. As
a part of the companys 2015 Sustainability Goals, the people at Dow are committed to using
resources more efficiently, providing value to their customers and stakeholders, delivering
solutions for customer needs and enhancing the quality of life of current and future
generations.
More information on sustainability and Dows 2015 goals can be found at
http://www.dow.com/commitments/
Dows 2015 Goals are divided into the seven categories listed below:
Local Protection of Human Health and the Environment
By 2015, Dow will achieve on average a 75 percent improvement of key indicators for EH&S
operating excellence from 2005 baseline. We will also collaborate with our communities to set
and commit to local sustainability goals
Contributing to Community Success
By 2015, 100 percent of Dow sites where we have a major presence will have achieved their
individual community acceptance ratings. Dow will complete the community relations
assessment process to evaluate its impact on site communities and will implement a
community relations plan that requires periodic re-evaluation. Dow will identify the targeted
community area surrounding, adjacent or very near the manufacturing facilities or related Dow
operations most likely impacted by Dows presence, and where Dow is impacted by the
communitys acceptance level. An anonymously conducted sustainable community assessment
will be conducted to define what is needed to achieve the desired quality of life.
Product Safety Leadership
By 2015, Dow will make publicly accessible safety assessments for its products globally, and in
doing so will address relevant gaps in hazard and exposure information. It will continue to take
appropriate action based on the assessments to protect human health and the environment
throughout the life cycle.
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 36 of 37
Verification report for Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. & Rohm & Haas
Canada LP., December 2010
Page 37 of 37