Housekeeping

To keep work areas, materials, and equipment safe, Dow Aero ("Company") has developed the following housekeeping program for maintaining its expansive operations clean, orderly, and sanitary. These measures are intended to limit employee exposures to hazardous conditions and eliminate unnecessary risks.

Housekeeping should be a team effort. Designated worker responsibilities will help engage all workers in good housekeeping practices. This established program identifies the responsibilities of each job or work area, and assign a frequency for conducting those tasks. Workers should be responsible for keeping their work areas tidy during their normal shift, as well as at the end of their shift, to ensure that the work area is clean, organized, and free of debris or obstructions. This is particularly important in areas where routine maintenance or cleaning may be conducted after regular working hours. It is also important that unused equipment and materials are returned to their proper storage location as soon as possible, but no later than the end of the work shift. Further, hazardous materials and waste products should be stored or appropriately discarded when they are no longer in use. Employees and Company management should also inspect the facility at regular intervals and at the end of the work day to ensure that good housekeeping practices are effective.

Effective housekeeping is an ongoing duty...it is not a one-time or hit-and-miss cleanup done occasionally. Periodic "panic" cleanups are costly and ineffective in reducing incidents. 

Due to the wide array of subjects housekeeping can cover, the following program details may be in unison with other Company health and safety programs, whether in-whole or in-part, to improve communication of safe working practices. For further information on specific health and safety policies (i.e., Injury and Illness Prevention, Fire Safety, Electrical Safety, etc.), refer to the more specific program..

This program has been developed in an effort for the Company to maintain compliance with Occupational Safety and Health Administration (OSHA) Rule CFR 1915.88, along with other supporting rule(s). If discrepancies exist between this policy and OSHA regulation, the regulation shall govern and the Company's Environmental Health & Safety (EHS) department shall be notified immediately.

Responsibilities

Environmental Health & Safety (EHS)

The Company's EHS department shall:

  • Implement the housekeeping program; and

  • Enforce all safety policies, procedures, guidelines, and verify safe work practices are maintained.

Department Leads

The Company's department leads shall:

  • Continually conduct safety checks of operations within their designated departments; and

  • Ensure their employees follow the program and other safety policies, procedures, guidelines, and establish safe work practices.

Managers and Supervisors

The Company's managers and supervisors shall:

  • Continually conduct safety checks of operations within their designated work areas; and

  • Ensure their employees follow the program and other safety policies, procedures, guidelines, and establish safe work practices.

Employees

All employees must:

  • Follow the instructions of this program and their superiors orders;

  • Report any unsafe or hazardous conditions or acts that may cause injury to either themselves or any other employees and visitors; and

  • Keep work areas uncluttered, orderly, sanitary, and free of other hazards that could result in personal injury or injury to others.

Housekeeping Safe Work Practices

All employees play a vital role in the implementation and execution of following safe work practices for housekeeping, regardless of location or department.

Emergencies

  • All evacuation routes are clearly marked and unobstructed;

  • All emergency-related signs, placards, posters, notices, and markings are clearly visible and legible at all times; and

  • Post-emergency cleanup operations will be conducted by personnel trained and authorized to perform specific cleanup tasks.

Select here for the Emergency Protocols for more details >

Common Areas

  • Dispose of general waste as appropriate;

    • DO NOT discard paper in sinks, urinals, or on the floor.

  • Dirty dishes or utensils may not be left unwashed;

    • Keep personal reusable cups and bottles in your workspace.

  • Space heaters shall be turned off when not being observed or at the end shift;

  • Turn off hot coffee pads when pots are empty or at the end of shift;

  • Flush toilets after use and unclog if necessary;

    • Disinfect and clean surfaces regularly, or as spills occur.

    • DO NOT flush wet wipes, even if they are labeled as "flushable".

  • Sanitarily cleanup nasal mucus discharge and other bodily fluids;

  • Replace paper towel and toilet paper rolls once emptied; and

  • Immediately refill water dispensers when emptied.

Working Surfaces

  • Keep all walking and working surfaces clean, sanitary, and orderly;

  • Keep work surfaces dry;

    • Clean up small spills immediately; and

    • Report large spills to a direct or indirect superior, department lead, or the Company's Environmental Health & Safety Department (EHS);

  • Ensure that all working surfaces are free from obstacles.

Walking Surfaces 

Floors

  • Place wet floor warning signs after any spills.

    • Clean up small spills immediately.

    • Report large spills to a superior, department lead, or the Company's Environmental Health & Safety Department (EHS).

  • Eliminate uneven floor surfaces.

    • e.g., bulging carpets, holes, misaligned boards.

  • Promptly remove combustible scrap, debris, and waste by discarding them according to state or local laws.

  • Verify proper drainage or mats are used in areas where standing water and substances can collect.

    • Use waterproof footgear or non-skid coatings to decrease slip and fall hazards in areas that are frequently wet.

Select here for the Slip, Trip, and Fall Prevention program for more details >

Aisles and Passageways

  • Keep aisles and passageways clear and marked as appropriate;

  • Anchor or cover temporary electrical cords that cross pathways;

  • Ensure there is safe clearance for walking in aisles where motorized or mechanical handling equipment is operating; and

  • Store materials or equipment in such a way that sharp projections will not interfere with or protrude into aisles or passageways.

Select here for the Slip, Trip, and Fall Prevention program for more details >

Select here for the Powered Industrial Truck Safety program for more details >

Elevated Surfaces

  • Pile, stack, or rack material on elevated surfaces in a manner that will prevent the material from tipping, falling, collapsing, rolling, or spreading.

  • Use dock boards or bridge plates when transferring materials between docks or trucks.

Select here for the Powered Industrial Truck Safety program for more details >

Entryways and Exits

  • All entryways and exits shall be kept clean, dry, and clear of all obstructions.

Select here for the Fire Prevention & Safety program for more details >

Stairs

  • All stairways shall be kept clean, dry, and free of debris.

  • No accumulation of any material will be allowed on stairs, stairways, or stairwells.

Select here for the Fire Prevention & Safety program for more details >

Lighting

  • Ensure that all halls and stairwells are well lighted to help reduce accidents and promote security.

  • Replace lightbulbs or fixtures as necessary to maintain adequate lighting at all times.

Fire & Explosion Prevention

Flammable materials and residues must be controlled with proper storage and remain away from ignition sources to prevent a fire emergency.

Maintenance of Ignition Sources

  • Equipment and systems installed on heat- or ignition-producing shall be maintained to prevent the accidental ignition of combustible materials; and

    • Examples of ignition sources include HVAC units, painter booth heaters, welding equipment (including torches), or any spark-producing equipment

  • Keep dry combustibles such as paper, cardboard, wooden pallets, or rags in designated locations away from ignition sources.

    • The accumulation of such material provides a place for a fire to start and spread quickly.

Flammable Substance Storage

  • No open flames, smoking, sparks, or welding will be allowed in storage areas with flammable substances;

  • Electrical equipment must be explosion-proof if flammable substances will be stored nearby;

  • Keep flammable substances away from direct sunlight and stored in a cool, dry place;

  • Storage areas must be well ventilated to prevent vapors from building up;

  • Store oxidizers and other incompatible materials away from combustible substances to prevent a dangerous reaction;

  • Use secondary containment methods to make sure any spills are contained; and

  • Return flammable substances to their storage location immediately after use.

Select here for the Hazardous Communication program for more details >

Used Rags

  • Put rags soaked with flammable substances in approved containers accordingly. 

Reactive Materials

  • Do not store reactive materials near one another.

    • Reactive materials, when mixed, often create an exothermic reaction, which produces heat and could cause these materials to combust spontaneously.

Electrical and Hot Equipment

  • Keep combustible dust and fuels away from electrical equipment and hot machinery;

  • Maintain a clear access to electrical panels at all times so that they can be opened quickly in case of an emergency that requires the power to a machine or the building to be shut down.

Select here for the Electrical Safety program for more details >

Fire Exits

  • Always keep evacuation routes clear;

  • Don't store boxes or items in aisles, hallways, or stairwells that lead to emergency exits; and

  • Ensure that exit doors are kept clear on both sides to be easily opened in an emergency.

Select here for the Fire Prevention & Safety program for more details >

Fire Extinguishers

  • Fire extinguishers shall not be used as hangers for coats, air hoses, electrical cords, or anything else;

  • Access to extinguishers must be kept clear at all times;

  • Extinguishers shall always be kept visible; and

    • DO NOT block with stacks of boxes, forklifts, or other items.

  • All used emergency and fire-fighting equipment shall be replaced or serviced after use; and

Select here for the Fire Prevention & Safety program for more details >

Combustible Dust

Combustible dusts that accumulate on surfaces can cause a deflagration, other fires, or an explosion. Combustible dusts are often either organic or metal dusts that are finely ground into very small particles, fibers, fines, chips, chunks, flakes, or a small mixture. These dusts include, but are not limited to: 

  • Metal dust, such as aluminum and magnesium;

  • Wood dust;

  • Coal and other carbon dust;

  • Plastic dust and additives;

  • Biosolids;

  • Other organic dust, such as sugar, flour, paper, soap, and dried blood; and

  • Certain textile materials.

Criteria for Dust Cleanup

  • Immediate cleaning and collection of accumulated combustible dust are warranted whenever a layer of combustible dust 1/32-inch thickness (i.e., approximately the thickness of a typical paper clip) accumulates over a surface area of at least 5 percent of the floor area of the facility or any given room.

    • Accumulations on overhead beams, joists, ducts, the tops of equipment, and other surfaces should be included when determining the dust coverage area.

    • Vertical surfaces will be included if the dust is adhering to them.

    • Likely areas of dust accumulations within a facility are:

      • Structural members;

      • Conduit and pipe racks;

      • Cable trays;

      • Floors;

      • Above the ceiling; and

      • On and around equipment (leaks around dust collectors and ductwork). 

Procedures for Dust Cleanup

  • Routinely remove accumulations of combustible dust from elevated surfaces, including the overhead structure of buildings.

  • Accumulations shall be removed and collected in dust collectors or vacuum cleaners as appropriate.

Waste Recycling and Disposal

  • Scrap materials shall be collected and sorted for recycling or disposal;

  • Scrap containers will be placed near areas where the waste is produced to encourage orderly recycling or disposal;

  • Waste receptacles that are dedicated to specific waste shall be clearly labeled; and

  • Waste shall be disposed of as appropriate.

Hazardous Chemical Spill Control

Spill Prevention

  • Machines and equipment, particularly CNC devices, shall be regularly inspected, cleaned, and maintained.

    • Incase of a spill, refer to the Spill Kit within designated sections of an appropriate work area. 

Electrical Parts and Equipment

  • Employees shall not perform housekeeping duties near live electrical parts where there is a possibility of contact unless adequate safeguards are present.

Select here for the Electrical Safety program for more details >

Extension Cords

  • Electric extension cords shall be inspected before each use and kept in good condition;

  • Employees must not yank cords from electrical outlets;

  • Tools and equipment that require grounding will be of the three-wire grounded-connection type;

  • Never use extension cords to replace permanent wiring;

  • If an extension cord is used for temporary wiring, it must be listed by Underwriters Laboratories or another recognized testing laboratory;

  • Avoid kinking or excessive bending of the cord; and

    • Broken strands may pierce the insulated covering and become a shock or short-circuit hazard.

  • Return extension cord to appropriate storage location after use.

Select here for the Electrical Safety program for more details >

General Storage

  • Store or stack materials to allow three (3) feet or more clear space under water sprinkler heads;

  • Stack cartons and drums on a firm foundation and cross-tie where necessary to reduce the chance of their movement; and

  • Do not allow stored materials to obstruct aisles, stairs, exits, fire equipment, emergency eyewash stations, first aid stations, etc.

    • All storage areas must be clearly marked.

Machine and Tools

Machines

  • Keep the area around machines clear of combustibles, slip and trip hazards, or any other debris;

  • Inspect machines before use;

  • Ensure that all guards are in place and operating correctly;

  • When finished using the machine, put away tools and clean up both the machine and the work area.

Select here for the Hazardous Energy Control program for more details >

Hand and Power Tools

  • Store blades and sharp tools carefully so that they do not create a hazard when not in use;

    • New blades for band saws, circular saws, or utility knives shall be placed/remain in labeled boxes or locations.

  • Keep blades on utility knives sheathed or retracted when not in use; and

  • When it's time to discard an old blade, discard directly into a blade container or cover the sharp edge with tape or cardboard.

Personal Protective Equipment

Personal Protective Equipment ("PPE") will not be used as a substitute for engineering, safe work practice, or administrative controls for preventing exposure to recognized physical or chemical hazards. PPE for housekeeping operations include:

  • Eye protection;

  • Gloves;

  • Proper shoes;

  • Dust masks; and

  • Other items such as protective clothing, respirators, and hearing protection, depending on the hazards.

Employees involved in housekeeping activities will implement the following PPE use and care procedures:

  • Inspect PPE before each use, checking for signs of wear or damage;

  • Keep PPE clean;

  • Store PPE properly according to appropriate instructions to prevent damage or contamination from dirt or chemicals; and

  • Replace PPE when it is worn out, damaged, or no longer provides the required protection

Select here for the Personal Protective Equipment program for more details >

Inspections

Programs related to housekeeping shall be regularly monitored to ensure a high standard of sanitation and safety in all work areas and identified deficiencies. The appropriate designee(s) will conduct regular inspections of work areas to monitor hazards and ensure that housekeeping safe work practices are implemented.

The appropriate designee(s) will develop housekeeping inspection schedules and checklists for each work area with specific hazards or work processes that differ from those found in the facility as a whole.

Frequency of Inspections

The frequency of inspections for each work area will be determined by identification of hazards and control recommendations from hazard assessments, deficiencies identified in previous inspections, frequency of changes in work processes, and any other factors that may affect compliance with housekeeping requirements and policies.

Random inspections may be conducted at anytime.

Inspection Documentation

Inspection checklists or reports will be kept within iAuditior or other documented methods. Each report will generally be maintained for a minimum of two (2) years after the inspection date. 

Training

The Company's Human Resources Information System (HRIS), currently BambooHR, shall generally distribute housekeeping and other assorted training material to all employees at the time of hire and as needed thereafter.

Management shall routinely perform safety meetings or talks to their employees and individuals who fail to follow safe practices.

Training Records

Training will be maintained by the Company’s Human Resources (“HR” department as appropriate. These records will generally be maintained for a minimum of three (3) years. 

Recordkeeping

Copies of all hazard assessments, inspection checklists, and accident reports will be maintained in accordance with appropriate recordkeeping requirements.



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