2010_dow rcms responsible care report

RESPONSIBLE CAREVerification Report

Dow Chemical Canada ULCDecember 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


EXECUTIVE SUMMARY AND TEAM CONCLUSIONS

This report documents the observations and conclusions of the independent verification team tasked with conducting a Responsible Care Verification of Dow Chemical Canada ULC., Dow AgroSciences Canada Inc. and Rohm & Haas Canada LP. The verification was carried out between November 23 and December 16, 2010. It included team visits to the Rohm & Haas manufacturing site in West Hill, Toronto along with those for Dow Chemical Canada Prentiss, Alberta and Varennes, Quebec. Corporate headquarters for Dow Chemical Canada and Dow AgroSciences in Calgary, Alberta were also visited. The verification team also conducted telephone interviews with other company personnel at locations the team was unable to visit. This was the fifth Responsible Care verification completed for Dow Chemical and Dow ArgoSciences Canada and the fourth for the Rohm and Haas facility. The last verification for Dow Chemical and Dow AgroSciences was completed in March, 2007 and for Rohm & Haas in March, 2005, before being acquired by Dow Chemical in 2009. As a result of the examination conducted, the verification team is of the opinion that the Responsible Care Ethic and Principles for Sustainability are guiding company decisions and actions, and that a self-healing management system is in place to drive continual improvement. The team believes that the company is capable of responding to the range of Findings Requiring Action identified during the verification - summarized below and discussed in detail in the report. The verification is complete and no further involvement is required by the verification team.

Signed: Date: April 6, 2011 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 [email protected] www.dowcanada.com


Summary of Verification Team Observations

Following is a listing of all Findings Requiring Action, Best Practices / Extra Miles and Opportunities For Improvement, found in the body of the text. In all, the team recorded 5 findings and 43 Opportunities for Improvement. Progress on action to resolve the Findings will require follow-up at each Leadership Group Meeting, with the local CAP(s), in the companys annual CEO re-commitment to CCPA and, along with the decisions pertaining to the Opportunities, in the next Responsible Care re-verification. The wording of each Finding Requiring Action, Opportunity and other comments found in this Executive Summary is identical to the wording used in the body of the report to avoid any possible misunderstanding of the teams intent. Findings Requiring Action:

i) It is a finding requiring action that the plan and check elements of ODMS, related to services provided to Dow Canada by parent Dow service providers, be reinforced to ensure that detailed Canadian Responsible Care code requirements and expectations are being met.

ii) At the Varennes site, develop and implement a management system to ensure that their recyclers (e.g. current recycler of plastics, wood, metal etc.) meet the requirements and expectations of the Manufacturing Code of Practice.

iii) 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.

iv) 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.

Best Practices/Extra Miles

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.

The scope of the entire documented Operations Discipline Management System which is based upon the plan-do-check-act continual performance improvement cycle, with defined links to the Responsible Care Codes of Practice.

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.

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.

The public publishing of Dows Corporate Sustainability Goals. The linking of performance targets to individual pay increases at all organizational levels at

Dow Chemical Alberta sites. The comprehensive list of leading performance indicators. The entire documented process safety management system, which is comprehensive and

completely addresses state of the art aspects of process safety. The Layers of Protection Analysis (LOPA) program which identifies site-specific process

hazards and identifies actions to mitigate those hazards.


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. Opportunities for Improvement: Works in Progress-

Complete current plans at the Rohm & Haas West Hill site to transition from their current management system to Dows ODMS.

At the DowAgroSciences Highland Seeds acquisition, complete current plans to fully implement Responsible Care and Dows ODMS.

Complete existing plans at the Varennes site to update level 3 EH&S policies (VS-X documents) to meet Corporate ODMS standards.

Complete current plans to clearly document the safe operating envelope for the Prentiss LP7 facility by the June, 2011 completion target.


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 follow-up 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.).


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 re-verification 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.


Consider providing a simplified overview of the Layers of Protection analysis program to Community Advisory Panels.

The CIAC Executive Contact should consider meeting face to face with the CAPs to introduce himself and engage in dialogue.

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 Advisory Panel sessions.

At West Hill CAP meetings, include community emergency notification as an agenda topic at prescribed intervals.

Establish a formal process for ongoing communications with near neighbours at the Sturgeon County and Varennes sites.

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

Upgrade the customer pick up equipment checklist at the Varennes site to include roadworthiness items.

Ensure that Dows corporate carrier selection process includes formal standards to be applied to load brokers

1. INTRODUCTION AND OVERVIEW

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.


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) Expectations of CIAC members and partners Each CIAC member or partner company must formally commit to the ethic, principles and codes of practice of Responsible Care as a condition of membership in the association. Progress in implementing these obligations must then be reported to CIAC, both to peers at special networking meetings and also via a formal reporting system to the association. Three years is the typical time allowed to new members for implementation. The association monitors progress and follows up by arranging for assistance where necessary to ensure that each company eventually meets its commitment. When a company considers that its management processes are sufficiently comprehensive that they meet each of the 151 individual code requirements, it advises the association that implementation is complete to the stage of Responsible Care-in-Place. Completion in this sense does not imply that nothing further needs to be done, but that a key milestone has been reached in a process of continuous improvement.

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.


1d) i) Verification of Responsible Care-in-Place For the purposes of this examination, a portion of the 151 code requirements is sampled in depth. These items are grouped into seventeen management systems, each of which is examined using a series of questions. Some of the questions are sent to the company in advance of the verification visit, so that supporting documentation, etc. can be available for prompt examination if desired. Additional questions are asked at the discretion of the team during the visit. The approach is top-down rather than the bottom-up used in conventional audits, and the style of questions is intentionally open-ended, so that the answer cannot be a simple yes/no but calls for explanation. The questioning process starts with the executive responsible for chemical operations in Canada, and works down through the organization to examine the senior level intent and the corresponding support by action at the operating level. Questions are generally of the following nature: does the organization have an effective management system in place to ensure

understanding of Responsible Care? what is the process to determine and communicate the acceptable level of performance? what is the process for assessing the performance of the system and effecting follow-up to

meet or exceed the acceptable level of performance? what is the process for ensuring up-to-date documentation? do sufficient resources appear to be, or are thought by employees to be, in place? The findings are summarized in a report which highlights: actions required by the team before they consider the company meets the expectations of

Responsible Care; opportunities for improvement, which are recommended but not mandatory; recognition of any exemplary practices of the company which could be a model for other

CIAC members. The report is given to the company and CIAC, and the company is expected to share the report with interested persons in its communities as part of its dialogue process. If the team considers that actions are required before sign-off, they will arrange for follow-up to confirm that these are complete, and advise the company and CIAC in writing when these have been met to their satisfaction. Responsible Care-in-Place verifications of Dow Chemical Canada ULC. Company name at time: Dow Chemical Canada Inc. Date of verification (visit): November 28-30, 1994 Locations visited: Sarnia, Ontario and Fort Saskatchewan, Alberta Team follow-up needed: No Date of final sign-off: January, 1995 Company name at time: Union Carbide Canada Ltd. Date of verification (visit): December 12-14, 1995 Locations visited: Montreal, Quebec, Prentiss, Alberta Team follow-up needed: Yes Date of final sign-off: April 25, 1997 Responsible Care-in-Place verification of Dow AgroSciences Canada Inc.


Company name at time: Dow Elanco Canada Inc. Date of verification (visit): November 4-6, 1996 Locations visited: Calgary Headquarters, Sturgeon County plant site and Edmonton Research Farm, all in Alberta Team follow-up needed: No Date of final sign-off: November, 1996 Responsible Care-in-Place verification of Rohm & Haas Canada LP Company name at time: Rohm & Haas Canada Inc. Date of verification (visit): April 4-6, 1995 Locations visited: West Hill, Ontario Team follow-up needed: Yes Date of final sign-off: September 3, 1995 This Responsible Care-in-Place verification reports are available from the contact at the company from whom you accessed this report, or from the company contact shown on page 2 of this re-verification report.

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 broad-ranging review of the companys management systems for Responsible Care, with a special investigation into certain topics highlighted by CIAC in the verification protocol.


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: Rohm & Haas Canada Inc. Date of verification (visit): February 28- March 1, 2005 Locations visited: West Hill, Ontario Team follow-up needed: No Date of final sign-off: May 31, 2005 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. GENERAL FINDINGS OF THE TEAM 2a) Statement on the Responsible Care Ethic


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) Overall Responsible Care Management System It is a requirement of Responsible Care that companies have documented, sound management systems capable of ensuring that all operations of the company across all business units, functions and sites meet the ethic, codes of practice and other expectations of Responsible Care on an ongoing basis. A sound management system drives continuous improvement, and has the following attributes: Plan - review code requirements - benchmark best practices - get input from stakeholders - decide on best approach - set targets for performance - assign responsibility Do - document - train people - assign resources - carry out activities Check- audit - measure performance of system - measure performance from system


- obtain stakeholders feedback - assess employees performance Act - follow-up on audit findings - communicate performance, get feedback - reward or correct employees - repeat Plan steps

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. Self-assessments 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.


Training is managed through a computerized system referred to as My Learning, which is used to specify and log training for employees. The Re-verification team observed that Canadian Responsible Code requirements and expectations which are implemented by the Canadian organization are appropriately referenced and documented in ODMS. However, these were less clearly defined when services were performed by the parent company from other jurisdictions, primarily in the USA. Examples include the Product Stewardship, Transportation & Distribution code areas. The Dow AgroSciences 2010 Environment, Health and Safety (EH&S) Integrated Audit of their Saskatoon site showed a trend where follow-up actions were not completed according to schedule. Dows recently acquired Rohm and Haas West Hill site is in the process of implementing Dows ODMS. Hyland Seeds, acquired by Dow AgroSciences, is also in the process of implementing Dows ODMS, along with Responsible Care. FINDINGS REQUIRING ACTION: i) It is a finding requiring action that the plan and check elements of ODMS, related

to services provided to Dow Canada by parent Dow service providers, be reinforced to ensure that detailed Canadian Responsible Care code requirements and expectations are being met.

ii) At the Varennes site, develop and implement a management system to ensure that their recyclers (eg; current recycler of plastics, wood, metal etc.) meet the requirements and expectations of the Manufacturing Code of Practice.

Opportunities for Improvement: i) Persons doing self assessments should consider including individuals from other areas to

bring a broader perspective to the review. ii) At Dow AgroSciences Canadas Saskatoon site, establish a process to ensure that follow-

up 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.

iii) Complete current plans at the Rohm & Haas West Hill site to transition from their current management system to Dows ODMS.

iv) At the DowAgroSciences Highland Seeds acquisition, complete current plans to fully implement Responsible Care and Dows ODMS.

v) Complete existing plans at the Varennes site to update level 3 EH&S policies (VS-X documents) to meet Corporate ODMS standards.

vi) 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

Best Practices: i) The scope of the entire documented Operations Discipline Management System which is

based upon the plan-do-check-act continual performance improvement cycle, with defined links to the Responsible Care Codes of Practice.


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) Follow-up on Findings in Last Verification Report

The team reviewed how the company addressed the findings requiring action and opportunities for improvement cited by the previous verification team in their report to the company. Certain follow-up items are covered in the specific topics below.

FINDINGS

Overview: During the 2007 Dow/Dow AgroSciences re-verification, the team recorded 13 Findings Requiring Action and 41 Opportunities for Improvement. The 2005 re-verification of Rohm & Haas Canada identified 3 Findings Requiring Action and 18 Opportunities for Improvement. The status of the actions taken on the above were reviewed during this re-verification with one item from the 2007 Dow/Dow AgroSciences report remaining uncompleted and planned actions on all items in the Rohm & Haas report having been addressed. The last Dow /Dow AgroSciences verification report was initially shared with the companys Community Advisory Panel (CAP) members at the Prentiss and Fort Saskatchewan as was the Rohm & Haas report to their West Hill CAP. The Dow/Dow ArgoSciences report was also made available on the companys internal intranet and external internet websites. The Dow/Dow AgroSciences report was not formally communicated at the Varennes site. Opportunities for Improvement: i) 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.

2d) Response to Incidents and Concerns since the last Verification Since the way in which unplanned situations are handled shows the influence of the Responsible Care ethic and responsiveness of the management system, the team looked at the issues, incidents and concerns that have arisen since the last verification and how the company has handled them. Some of these may be covered under individual topics below, as noted.

FINDINGS

Overview:

A comprehensive process, utilizing established investigation methodology, is used to analyze incidents, unplanned events, and non-conformances, as well as near misses. Actions aimed at preventing recurrence are identified, with appropriate follow up and communication of lessons learned. The Event and Acton Tool noted in section 2b) of this report is used to ensure follow-up actions are tracked to completion.


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. TEAM FINDINGS FOR SPECIFIC CODE MANAGEMENT SYSTEMS

3a) Process Safety Management (PSM)


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) Site Security & Emergency Response


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.


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.


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


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) Visibility & Employee Awareness of Responsible Care Here the team looked at how the company seeks to make Responsible Care a visible part of its facilities and its internal and external communications, and how it ensures that all employees


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 re-verification visits could serve as an excellent tool for widespread use in this regard.

3f) Workplace Health & Safety The team looked at the companys processes for continuous improvement in protecting the safety and health of employees, contractors and visitors.

FINDINGS

Overview: There is a clear focus evident on continually improving the companys health and safety performance, through a belief that all occupational injuries and illnesses are preventable. Dows global corporate 2015 Sustainability Goal target is to drive its Injury and Illness rate to no more than 0.12 incidents per 200,000 hours, representing a 75 percent reduction form 2005. Their documented health and safety program addresses identification and evaluation of hazards, behavioral expectations, and operational controls and procedures. There is also a documented program in place, which outlines the requirements for ensuring the health and safety of contractors and visitors.


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) Site Risk Communications

The team looked at the companys management system for ongoing communication and dialogue on the risks of its site operations with potentially affected communities.

FINDINGS

Overview: In November 2008, the Prentiss site conducted a public meeting to discuss its worst case and emergency planning scenarios. All neighbours within three kilometres received an invitation,


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) Dialogue Process with Communities The team looked at how the companys broader process for dialogue with its communities has been working since the previous verification, including the identification of stakeholders, community issues and concerns, how concerns were addressed and the choice of dialogue


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.


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


ii) Contributing to Community Success iii) Product Safety Leadership iv) Breakthroughs to World Challenges v) Energy Efficiency vi) Climate Change vii) Sustainable Chemistry

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) Engagement with Elected Officials Since part of Responsible Care is a commitment to assist in the processes of sound public

policy development consistent with the criteria for sustainable development, the team reviewed the companys process for establishing ongoing relationships with elected officials (i.e., MPs, MLAs, city councillors, etc.) in constituencies where the company has a presence, to acquaint those officials with the nature of the companys operations, economic impact, Responsible Care commitment, activities and public policy concerns, and to understand the elected officials interests and concerns. Also reviewed were the companys engagement in CIAC activities aimed at assisting in the development of sound public policy (e.g., Parliamentary Day, policy discussions, lobbying, etc.).

FINDINGS

Overview: The company actively ensures on-going relationship with local elected officials in all areas visited as well as other provincial and Canadian elected officials. Many of the activities are initiated via the various industry groups / committees in which the company participates. This includes such activities as Parliamentary Days in Ottawa and the October Senior Government Officials Meeting in Edmonton. Elected officials are also engaged through company sponsored community events. In addition, Dow leadership have participated in meetings with the Premier of Alberta and Finance and Enterprise team in support of growth in Alberta.


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.


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) Companys Requested Areas for Team Focus The Company identified the following two areas that it particularly wanted the team to explore:

A- Sustainability and B- Decommissioning and Demolition of Assets Team comments on Sustainability are documented in section 3i) above and those on Decommissioning and Demolition are as follows: Several significant Dow Canada plant closures have occurred in recent years including the decommissioning and demolition of facilities in Weston and

2010_dow rcms responsible care report

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