2010 - Dow Rcms Responsible Care Report

RESPONSIBLE CARE
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
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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.
Date: April 6, 2011
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
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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.
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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.
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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.).
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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.
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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.
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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.
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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
Yes
Date of final sign-off: April 25, 1997
Responsible Care-in-Place verification of Dow AgroSciences Canada Inc.
Page 10 of 37
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
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
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 broadranging review of the companys management systems for Responsible Care, with a special
investigation into certain topics highlighted by CIAC in the verification protocol.
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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
No
Date of final sign-off:
November 6, 2007
Company name at time:
Date of verification (visit):
Locations visited:
Date of final sign-off:
Rohm & Haas Canada Inc.

February 28- March 1, 2005
West Hill, Ontario
No
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

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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
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Act
- obtain stakeholders feedback

- assess employees performance
- 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. 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.
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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.
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 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.
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.
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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.
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 followup actions are tracked to completion.
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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.
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)

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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.
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

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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.
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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.
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.
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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
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
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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
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
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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.
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)
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.
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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.
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,
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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.
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
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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.
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.
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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
Page 27 of 37
ii)
iii)
iv)
v)
vi)
vii)
Contributing to Community Success

Product Safety Leadership
Breakthroughs to World Challenges
Energy Efficiency
Climate Change
Sustainable Chemistry
The team observed organizational commitment and progress towards achieving these goals
during this re-verification
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.
Page 28 of 37
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.
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.
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)
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 Sarnia, Ontario and Fort
Saskatchewan, Alberta. This work was completed without injury or chemical overexposures to
workers, companies and contractors, no environmental occurrences and no unplanned
business interruptions. These excellent results were achieved as a result of detailed plans
being effectively implemented under the guidance and direction of Dows Global Demolition
Team
Best Practices:
i) Dows Decommissioning and Demolition process.
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
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
March 28, 2011
Page 31 of 37
APPENDIX 1
COMPANY DESCRIPTION & CHANGES
The Dow Chemical Company

Dow Chemical Canada ULC, Dow AgroSciences Canada Inc and Rohm & Haas Canada LP
are all directly or indirectly wholly owned subsidiaries of the Dow Chemical Company, which
includes an industry-leading portfolio of specialty chemical, advanced materials, agrosciences
and plastics businesses. In 2009, Dow had annual sales of $45 billion and employed
approximately 52,000 people worldwide. The Company's more than 5,000 products are
manufactured at 214 sites in 37 countries across the globe. More information about Dow can
be found at www.dow.com.
Dow Chemical Canada ULC, headquartered in Calgary, together with their affiliates have
approximately1000 employees. Manufacturing sites are located in Varennes, Quebec, Fort
Saskatchewan and Prentiss, Alberta; transforming resources and raw materials such as ethane
into value-added products Resale business also takes place in Canada for the numerous
products Dow makes globally. More information about Dow Canada can be found at
www.dowcanada.com
Dow AgroSciences Canada Inc.
Dow AgroSciences Canada Inc. is a research based, agricultural sciences company with a
diverse product portfolio including weed, insect and disease management for
agricultural/horticultural crops and products for forestry and industrial vegetation management.
Current priorities include the development of a plant genetics and biotechnology platform in
canola and corn. Field research capabilities are in place across western and eastern Canada
including a plant breeding and cell biology group based in Saskatoon, Saskatchewan. With
employees throughout Canada, the Dow AgroSciences head office is in Calgary, Alberta, with
a regional office in Saskatoon, Saskatchewan.
Rohm and Haas Canada LP
Rohm and Haas Canada LP is a wholly owned subsidiary of Rohm and Haas Company, which
is in turn a wholly owned subsidiary of The Dow Chemical Company since 2009. Rohm and
Haas is a specialty materials company, which makes products for the personal care, grocery,
home and construction markets, and the electronics industry. More information on Rohm and
Haas can be found at http://www.rohmhaas.com. The West Hill site is the only manufacturing
location for Rohm and Haas Canada
Changes since the March, 2007 Re-Verification
Change has been ongoing at Dow since the last re-verification. In April 2009, Dow announced
that it had completed its acquisition of Rohm and Haas globally. For Canadian operations, the
Rohm and Haas West Hill site, manufacturing water based acrylic emulsions in Toronto,
became part of the Dow Canada family of companies.
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:
Calgary, Alberta: Dow and Dow AgroSciences National Head Quarters

Prentiss, Alberta: Polyethylene manufacturing
Fort Saskatchewan, Alberta: Fractionator, Ethylene, Polyethylene, and Power and
Utilities operations
Varennes, Quebec: STYROFOAM polystyrene insulation
West Hill, Ontario: water based emulsions
Sturgeon County, Alberta: granular herbicides and packages liquid herbicide
(Glyphosate)
Saskatoon, Saskatchewan: plant breeding and cell biology research and development
group, Regional Office
St. Marys, Ontario: Dow AgroSciences Seed Research facility
Sarnia, Ontario: No manufacturing facilities, all facilities demolished and land has been
sold. Approximately 15 Dow personnel with corporate or global roles continue to work out
of the Sarnia area.
Page 33 of 37
APPENDIX 2:
TEAM AND CONTACTS
1.
The Verification Team

The verification team consisted of the following:
Name
Alec Robertson
Dave Mack
Marcel Emond
Jeff Perkins
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
Persons contacted at the company

Name
Position
Greg Johnston
Production Leader- R&H West Hill Site
Jim Hanna
Regulatory Affairs Specialist
Rohm and Haas Canada LP
Dale Stephenson
EH&S Delivery Leader-R&H West Hill Site
Wolfram Esser
HS&E Delivery Leader-R&H West Hill Site
Dave Shortt
Regulatory Affairs Leader & Leader-Dow Chemical Canada
Responsible Care Leadership Team
Elaine Wasylenchuk
Dow Chemical EH&S Regulatory Affairs Specialist/Overall
Responsible Care Code Coordinator
Ann Davis
EH&S Global Product Leader- Dow Chemical Midland, Michigan Via
teleconference
Brenda Harris
DAS, Regulatory & Government Affairs Manager-Via teleconference
Joanne West
Dow Canada Remediation Leader - via teleconference
John Deleeuw
Business External Manufacturing Leader(former Weston Site
Leader) Via teleconference
Bob Schroter
Responsible Care Leader/EH&S Specialist Dow AgroSciences
Brian Mills
Production Leader DAS Sturgeon County
Chris Voglewede
R & D Leader- DAS Canada
Jack Broodo
President, Dow Canada/Business Director Hydrocarbons & EnergyCIAC Executive Contact
Jim Wispinski
President & CEO, Dow AgroSciences
Mark Weick
Director, 2015 Sustainability Goals Program Management Office
(PMO)
Otto Parets
Production Leader, LP7 Polyethylene Operations/Prentiss
Rod Boshnick
Dow Prentiss Responsible Care Leader
Randy Brooks
Training & ODMS Coordinator Dow Prentiss
Neil Gongaware
EH&S Delivery Technician-Prentiss
Page 34 of 37
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
Process for obtaining information

The Re-verification process followed the June 2009 CIAC protocol for Responsible Care Reverification, and consisted of a series of interviews with management, support staff and hands
on employees, document reviews, and site inspections.
Visits were made to Rohm & Haas LPs facility in West Hill, Ontario, as well as to Dow Canada
ULCs headquarters in Calgary and facilities in Prentiss Alberta and Varennes Quebec. A Dow
AgroSciences Canada Inc, review was carried out via interviews with corporate management
and staff in Calgary along with teleconference interviews with various individuals including site
management and staff at their Saskatoon R&D facility. Meetings were also held with the
companys Community Advisory Panels at West Hill, Prentiss and Fort Saskatchewan to obtain
the perspective of local residents.
Page 35 of 37
APPENDIX 3
FACT-FINDING QUESTIONS RE NEW RESPONSIBLE CARE ETHIC & PRINCIPLES FOR

SUSTAINABILITY
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.
Page 36 of 37
Breakthroughs to World Challenges

By 2015, Dow will achieve at least three breakthroughs that will significantly improve the
worlds ability to solve the challenges of affordable and adequate food supply; decent housing;
sustainable water supplies; or improved personal health and safety.
Energy Efficiency
Dow will reduce energy intensity 25 percent from 2005 to 2015. Global Energy Efficiency Team
Leaders will lead implementation by driving the development of major site and business 2015
goals, and the development of specific plans to meet the goals. Global Energy Efficiency Team
members will define business and site-level goals, plans and action steps. Dow will use existing
systems and processes to track energy use, calculate intensity and report energy intensity.
Climate Change
We believe that climate change is one of the most serious issues our society faces today. The
worlds climate is impacted by increases in greenhouse gas (GHG) levels, and though the exact
results of this development are not yet fully understood, we will take aggressive action to
mitigate it. We are committed to being part of the solution for this issue through the products
we make, the science and technology we develop, and the way in which we optimize our own
processes. We also believe that the long-term nature of the climate change problem requires
different solutions over different timeframes. In the short-term (10-30 years), we will optimize
the use of existing energy sources, while we help drive the search for breakthrough energy
technologies and processes that will fundamentally address the problem long-term.
Dow has committed to a 2015 GHG intensity goal of 2.5% per year reduction in GHG
emissions per pound of produced product (from a 2005 baseline). A sustained 2.5% intensity
improvement between now and 2050 will significantly reduce Dows GHG emissions compared
to a Dow business-as-usual scenario...
Sustainable Chemistry
Sustainable chemistry is our cradle to cradle concept that drives us to use resources more
efficiently, to minimize our footprint, provide value to our customers and stakeholders, deliver
solutions for customer needs and enhance the quality of life of current and future generations.
As a leader in our global industry, Dow is uniquely positioned to innovate and reshape Dows
product portfolio and businesses to be more sustainable, and ultimately change the game in
our industry through more sustainable chemistry. Some steps in our journey will be dramatic
while others will seem incremental. However, taken collectively, they will allow Dow, and the
industry, to progress on a more sustainable course. Our goal is to increase the percentage of
sales to 10% for products that are highly advantaged by sustainable chemistry, according to
our Sustainable Chemistry Index.
Page 37 of 37
CHEMISTRY INDUSTRY ASSOCIATION OF CANADA

Suite 805, 350 Sparks Street
Ottawa (ON) K1R 7S8
T: 613 237-6215 F: 613 237-4061
www.canadianchemistry.ca

2010 - Dow Rcms Responsible Care Report

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RESPONSIBLE CARE

EXECUTIVE SUMMARY AND TEAM CONCLUSIONS

Date: April 6, 2011

Summary of Verification Team Observations

Opportunities for Improvement:

Consider providing a simplified overview of the Layers of Protection analysis program to

INTRODUCTION AND OVERVIEW

Expectations of CIAC members and partners

i) Verification of Responsible Care-in-Place

Company name at time: Dow Elanco Canada Inc.

Rohm & Haas Canada Inc.

GENERAL FINDINGS OF THE TEAM

Statement on the Responsible Care Ethic

Overall Responsible Care Management System

- obtain stakeholders feedback

Training is managed through a computerized system referred to as My Learning, which is used

Follow-up on Findings in Last Verification Report

Response to Incidents and Concerns since the last Verification

TEAM FINDINGS FOR SPECIFIC CODE MANAGEMENT SYSTEMS

Process Safety Management (PSM)

Site Security & Emergency Response

Visibility & Employee Awareness of Responsible Care

Workplace Health & Safety

Site Risk Communications

Dialogue Process with Communities

Contributing to Community Success

Engagement with Elected Officials

Companys Requested Areas for Team Focus

The Dow Chemical Company

Calgary, Alberta: Dow and Dow AgroSciences National Head Quarters

The Verification Team

Persons contacted at the company

Process for obtaining information

FACT-FINDING QUESTIONS RE NEW RESPONSIBLE CARE ETHIC & PRINCIPLES FOR

Breakthroughs to World Challenges

CHEMISTRY INDUSTRY ASSOCIATION OF CANADA

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