Injury and Illness Prevention
Dow Aero Logistics ("Company") makes any and all reasonable efforts to:
- Provide a safe workplace.
- Protect the health and safety of everyone on the job.
- Proactively identify and correct health and safety hazards.
- Encourage anyone to report potential or known hazards and/or violations.
- Make information easily available to employees and visitors about health and safety hazards.
Per Occupational Safety and Health Administration (OSHA), the Company has adopted an Injury and Illness Prevention Program (IIPP), which describes specific requirements for program responsibility, compliance, communication, hazard assessment, accident and exposure investigations, hazard correction, training, and recordkeeping.
To ensure compliance:
- Employees are trained and retrained, as necessary or as required.
- Health and safety practices are to be integrated into employee job descriptions.
- Retaliation shall not be tolerated for health and safety reports that are made in good-faith.
- Employees are recognized for following safe work practices (e.g. oral or written acknowledgments).
- Disciplinary actions against employees and visitors who fail to follow safe and healthful work practices are taken when appropriate.
Violence in the Workplace
The Company’s Violence in the Workplace guide provides guidance for responding to violence or threats of violence (see Violence in the Workplace).
The situation will dictate the roles and responsibilities of employees, supervisors, managers, and more. There are also specific procedures for responding to:
- Threats of violence.
- Acts of violence not involving injuries and/or weapons.
- Acts of violence involving injuries and/or weapons.
Everyone has the responsibility to ensure that fellow coworkers, contractors or other third parties, and visitors comply with safe and healthy work practices.
Environmental Health and Safety (EH&S)
The head of EH&S* is responsible for the Company's Health and Safety programs. This involves:
- Serving as lead liaison with OSHA and Environmental Protection Agency (EPA) representatives.
- Administering the Company's Injury and Illness Prevention Program and others.
EH&S is responsible for:
- Working with Human Resources, Quality Assurance, managers, supervisors, and/or employees to develop or maintain health and safety guidelines and policies.
- Ensuring that health and safety inspections and investigation records are kept and maintained for an appropriate period of time.
- Advising senior management, Human Resources, managers, supervisors, and/or employees on health and safety issues.
- Assisting supervisors in conducting workplace hazard assessments to identify, evaluate, and correct hazards.
- Preparing and distributing the Company’s guidelines, policies, and procedures on health and safety issues.
- Establishing, conducting and maintaining an injury/illness/accident report and investigation procedure.
- Providing training and technical assistance to managers and supervisors on implementation of the IIPP.
- Arranging health and safety inspections and follow-ups to insure corrective action is completed.
- Establishing a system for maintaining the records of inspection and hazard abatement.
- Reviewing, updating, and evaluating the overall effectiveness of the IIPP.
- Preparing and maintaining the Company’s injury and illness records.
- Developing a code of safe practices and inspection guidelines.
- Planning, organizing, and coordinating safety trainings.
- Reviewing injury and illness trends.
Human Resources (HR)
The head of Human Resources is responsible for:
- Serving as lead liaison with local, state, and federal employment representatives, with exception to OSHA and the EPA.
Human Resources is responsible for:
- Working with EH&S, managers, and/or supervisors to develop health and safety guidelines and policies that are in compliance with local, state, and federal employment regulations.
- Ensuring that employee health and safety records are kept, and maintained for an appropriate period of time.
Quality Assurance (QA)
The head of Quality Assurance is responsible for:
- Serving as lead liaison with FAA, EASA, and ISO EN/AS representatives.
Quality Assurance is responsible for:
- Working with EH&S, managers, and/or supervisors to develop health and safety guidelines and policies that are in compliance with FAA, EASA, and ISO EN/AS regulations.
Managers are responsible for ensuring that:
- Individuals under their management have the ability to implement appropriate health and safety policies, practices, and programs.
- Areas under their management are in compliance with the Company’s health and safety practices, policies, and programs.
- Areas under their management have adequate funding for health and safety programs, practices, and equipment.
Supervisors are generally responsible for enforcing the Company’s IIPP**. This includes:
- Confirming that workplaces and equipment are safe, well maintained, and in compliance with Company policies, programs, and practices.
- Ensuring workplace incidents (injuries, exposures, or illnesses) are reported, investigated, and that corrective actions are taken promptly.
- Ensuring periodic inspections are conducted and that identified health and safety deficiencies are corrected in a timely fashion.
- Verifying that workplace health and safety practices and procedures are clearly communicated and understood by employees.
- Acknowledging employees who make a significant contribution to the preservation of a safe workplace.
- Encouraging employees to report workplace hazards without fear of reprisal.
- Fairly disciplining employees who fail to follow health and safety practices.
- Evaluating employees on compliance with safe work practices.
As employees, we are all responsible for following the requirements of the IIPP. This involves:
- Promptly reporting potential hazards or workplace incidents (injuries, exposures, or illnesses) to your supervisor, EH&S, or HR.
- Staying informed of conditions affecting, or that could affect your health and safety or for any other person in the vicinity.
- Notifying coworkers or visitors when the person(s) is committing a safety violation.
- Participating in training programs as required, or as needed.
- Adhering to healthy and safe practices in your workplace.
* View the Department Heads that have been discussed in this program.
** Although responsibilities will generally be reflected as laid out above, certain arrangements may alter responsibilities on a case-by-case basis. Consult the position's job description for exact information.
The Company shall have procedures for identifying and evaluating workplace hazards, including periodic inspections to identify unsafe conditions and work practices. Supervisors shall generally be responsible for ensuring that periodic inspections are conducted and should consult with EH&S when requiring alterations to an inspection checklist.
Work area inspection schedule for supervisors, managers, and/or EH&S
Work area inspections shall be conducted:
- Upon initial establishment of the Injury and Illness Prevention Program (IIPP).
- Preferably in:
- Office areas annually.
- Shops and warehouses quarterly.
- When new substances, processes, procedures, or equipment, which present potential new hazards, are introduced.
- When new, previously unrecognized hazards are identified.
- When occupational injuries or illnesses occur.
Environmental Health and Safety (EH&S)
To assist supervisors in identifying and correcting potential hazards, EH&S may conduct formal or informal inspections and/or surveys.
Some outside agencies conduct regular, periodic inspections, which may assist the Company in achieving some of its inspectional responsibilities. These include:
- Federal Aviation Administration (FAA)
- OSHA Compliance Consultation (Coming Soon)
Recordkeeping of periodic inspections
EH&S shall maintain records of periodic inspections to identify unsafe conditions and work practices for at least one year. These records shall include:
- The person(s) conducting the inspection.
- Any description of the unsafe conditions and work practices.
- The actions taken to correct the identified unsafe conditions and work practices.
Reporting and Investigations
The Company shall investigate all workplace incidents (i.e. injuries, exposures, or illnesses).
Employees are to report a workplace incident to their direct supervisor as soon as possible. If unavailable, contact EH&S or HR at:
- Environmental Health and Safety
- Human Resources
Serious injuries, illnesses, or fatalities
OSHA defines an injury or illness as serious if it:
- Requires inpatient hospitalization for more than 24 hours, for reasons other than medical observation.
- An employee suffers any serious degree of permanent disfigurement.
- An employee suffers a loss of any member of the body.
- The supervisor must immediately contact EH&S through the following methods to report a serious injury or illness, or work-related death:
- EH&S must immediately report any serious injury, illness, or fatality to OSHA. Other incidents may be reported on a case-by-case basis.
- For more details, see Serious Injury/Illness Reporting Procedures.
Standardized forms for reporting and investigating workplace incidents
Supervisors, managers, and/or EH&S, shall complete the Incident Investigation Report within 24 hours after an incident involving employees, contractors or other third-parties, or visitors. If incident results in a death the report must be completed immediately.
If deemed necessary, corrective action shall occur promptly as feasible.
EH&S review of incidents
- All serious accidents and overexposures to chemical and/or physical stressors shall directly be investigated by EH&S immediately.
- For other incidents where additional follow-up is appropriate, EH&S will review submitted information to ensure that adequate corrective actions have been identified and implemented.
The Company is committed to correcting unsafe or unhealthy work conditions in a timely manner, based on the severity of hazards.
Correcting hazards schedule
Hazards shall be corrected as follows:
- When observed or discovered.
- When an imminent hazard exists that cannot be immediately abated without endangering employee(s) and/or property:
- All exposed personnel will be removed from the area, except those necessary to correct the existing condition.
- Employees necessary to correct the hazardous condition shall be provided with necessary safeguards.
Unsafe conditions that cannot be corrected with resources available to the supervisor or manager must be reported to the next level of management. Resources to correct hazards include the following:
- If the correction required relates to facility maintenance, the Company will address the repair without charge to the department.
- If the repair does not fall into the category of facility maintenance, departmental funds may be required.
- If sufficient departmental funds are not available, seek other resources from the Company.
As corrective actions are implemented, EH&S shall document the effort and maintain such records for at least one year.
Training and Instruction
The Company requires training of all employees to protect themselves from hazards in their work environment. Employees shall be trained in:
- Minimization of risks through sound safety practices and the use of protective equipment.
- Recognition and assessment of health and safety risks.
- Job-specific health and safety practices and hazards.
- Regulations and statutes applicable to their work.
- Company health and safety policies.
- General health and safety practices.
Tri-tier training program
The Company has organized its health and safety training system into a tri-tier program.
Tier one: General safety training
- General orientation is provided by Human Resources to all new employees.
- Orientation includes information on the Company’s health and safety policies and practices, employee health and safety rights, responsibilities, health and safety services at the Company, and expectations for further training.
Tier two: Hazard-specific training
- Hazard-specific training is provided by EH&S or other Company representatives, to employees in shops or other workplaces where special hazards may be encountered.
- Training topics include ergonomics, hazard communication, emergency response and evacuation procedures, and forklift safety.
- EH&S reviews tier two trainings for adequacy and consistency.
Tier three: Job-specific training
- Job-specific training is provided by supervisor's for employees and visitors as appropriate.
- Training consists of information specific to the hazards and equipment used by these employees. Is communicated by:
- Safety data sheets (SDS) and material safety data sheets (MSDS)
- Pamphlets and/or booklets
- Safety meetings
- EH&S reviews tier three trainings for adequacy and consistency.
Training shall be provided to all employees:
- When the Injury and Illness Prevention Program (IIPP) is first established.
- When new employees are hired.
- When employees are given new job assignments for which training has not been previously received.
- Whenever new substances, processes, procedures, or equipment are introduced to the workplace and represent a new hazard.
- Whenever the new or previously unrecognized hazard are discovered.
- When employees become supervisors (so that they can familiarize themselves with the health and safety hazards to which employees under their immediate direction and control may be exposed).
Training resources from EH&S
- EH&S assists the departments in providing health and safety training to employees on a variety of topics. These include IIPP training, shop safety training, respirator training, and others.
- EH&S is available to assist supervisors and managers in implementing training programs.
- Standardized forms for recordkeeping are available from EH&S.
- Documentation of health and safety training for each employee shall include:
- Employee name, identification number, or other identifier
- Training date
- Type of training
- Training provider
- The documentation shall be maintained for at least one year.
- Human Resources is responsible for maintaining these records.
- Employees may view their training records anytime via the Company's Human Resources Information System (HRIS).