Injury and Illness Prevention

Dow Aero ("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) regulatory requirements, the Company has adopted an Injury and Illness Prevention Program (“IIPP”). The IIPP describes specific requirements for program responsibility, compliance, communication, hazard assessment, accident and exposure investigations, hazard correction, training, and recordkeeping. To ensure compliance with the IIPP:

  • Employees are trained and retrained, as necessary or as required.

  • Retaliation is not 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.

Responsibilities

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 (EHS)

The highest ranking official for the Company’s Environmental Health & Safety (EHS) department is responsible for the Company's health and safety programs. This involves:

  • Serving as lead liaison with appropriate health and safety authorities.

    • e.g. Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), etc.

  • Administering the Company's IIPP and other health and safety programs.

The Company’s Environmental Health & Safety (EHS) department is responsible for:

  • Partnering with the Company’s Human Resources (HR) and/or Quality Assurance (QA) departments, along with department leads, managers, supervisors, and/or appropriate employees to develop, maintain, and distribute health and safety policies, procedures, protocols, guidelines, practices, and other materials.

  • Providing assistance to department leads, managers, and supervisors on implementation of the IIPP and other health and safety programs in their work environments.

  • Assisting appropriately assigned personnel in conducting workplace hazard assessments to identify, evaluate, and correct hazards.

  • Ensuring health and safety inspections and investigation records are kept and maintained for an adequate period of time.

  • Establishing, conducting, and maintaining Injury/Illness Accident Report records and investigation protocols.

  • Advising senior management, managers, supervisors, and/or employees of health and safety issues.

  • Establishing a system for maintaining the records of inspection and hazard abatement.

  • Reviewing, updating, and evaluating the overall effectiveness of the IIPP.

  • Developing a code of safe practices and inspection guidelines.

  • Planning, organizing, and coordinating safety trainings.

  • Reviewing injury and illness trends.

Human Resources (HR)

The highest ranking official for the Company’s Human Resources (HR) department is responsible for:

  • Serving as lead liaison with local, state, and federal employment representatives, with exception to OSHA and the EPA.

The Company’s Human Resources (HR) department is responsible for:

  • Working with the Company's Environmental Health & Safety (EHS) department, department leads, 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 injury and illness records are kept, and maintained for an appropriate period of time

Quality Assurance (QA)

The Company’s Quality Assurance department is responsible for:

  • Serving as lead liaison to Federal Aviation Administration (FAA), European Union Aviation Safety Agency (ESAS), and ISO EN/AS representatives.

  • Working with the Company's Environmental Health & Safety (EHS) department, department leads, managers, and/or supervisors to develop health and safety guidelines and policies that are in compliance with FAA, EASA, and ISO EN/AS regulations.

Department Leads, Managers, and Supervisors

Any department lead, manager, or supervisors is responsible for ensuring:

  • Their employee’s work areas and equipment are safe, well maintained, and in compliance with Company programs, policies, procedures, protocols, guidelines, and practices.

  • Individuals under their supervision have the ability to implement appropriate health and safety programs, policies, procedures, protocols, guidelines, and practices.

  • Areas under their management are in compliance with the Company’s health and safety programs, policies, procedures, protocols, guidelines, and practices.

  • Workplace incidents (injuries, exposures, or illnesses) are reported, investigated, and that corrective actions are taken promptly.

  • Workplace health and safety practices and procedures are clearly communicated and understood by their employees.

  • Periodic inspections are conducted, with identified health and safety deficiencies being corrected in a timely fashion.

  • Areas under their management have adequate funding for health and safety programs, practices, and equipment.

  • Acknowledgment of employees who make a significant contribution to the preservation of a safe workplace.

  • Encouragement to employees in reporting workplace hazards without fear of reprisal.

  • Fair discipline of employees who fail to follow health and safety practices.

  • Employees comply with safe work practices.

Employees

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 direct/indirect manager or immediate supervisor, department lead, or the Company’s Environmental Health & Safety (EHS) department.

  • 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.

** Although responsibilities will generally be reflected as laid out above, certain arrangements may alter responsibilities on a case-by-case basis. Consult a position's job description for further information. 

Periodic Inspections

The Company shall have policies, procedures, protocols, guidelines, and other materials for identifying and evaluating workplace hazards, including periodic inspections to identify unsafe conditions and work practices. Managers and supervisors, along with Department Leads, shall generally be responsible for ensuring that periodic inspections are conducted and updated when changes are made within their work environment; i.e. new equipment or revised processes.

Work Area Inspection Schedule

Work area inspections shall be conducted:

  • Upon initial establishment of the Injury and Illness Prevention Program (IIPP).

  • Preferably in:

    • Office areas semiannually.

      • i.e. every six (6) months.

    • Shops and warehouses areas every two (2) months.

  • When new substances, processes, procedures, or equipment arise which introduces potential hazards.

  • When previously unrecognized hazards are identified.

  • When occupational injuries or illnesses occur.

Environmental Health and Safety (EHS)

To assist managers and supervisors, along with Department Leads, in identifying and correcting potential hazards within their work environments, the Company’s Environmental Health & Safety (EHS) department may conduct formal or informal inspections and/or surveys at random.

Outside Agencies

Some outside agencies may conduct regular, periodic inspections, which may assist the Company in achieving some of its inspectional responsibilities. These can include:

  • Federal Aviation Administration (FAA)

  • OSHA Compliance Consultation

Recordkeeping of Periodic Inspections

Department Leads and/or the Company’s Environmental Health & Safety (EHS) department shall maintain records of periodic inspections that identify unsafe conditions and work practices for at least one (1) 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 reported incidents (i.e. injuries, exposures, or illnesses).

Reporting

Employees are to report any workplace incident to their manager or supervisor as soon as possible. If unavailable, contact:

Serious Incidents

Occupational Safety and Health Administration (OSHA) defines an injury or illness to a person as serious if it:

  • Requires inpatient hospitalization for more than twenty-four (24) hours, for reasons other than medical observation;

  • Any serious degree of permanent disfigurement occurs; and/or

  • Loss of a limb or any other member of the body.

The Company’s Environmental Health and Safety (EHS) department shall be immediately notified of a serious work-related injury, illness, or death via:

EHS shall immediately report any serious work-related injury, illness, or fatality to OSHA. Other incidents may be reported on a case-by-case basis.

Select here for more details from the Company’s serious injury/illness reporting protocols >

Standardized forms for reporting and investigating workplace incidents

Supervisors, managers, and/or EHS, 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.  

EHS Review

  • All serious accidents and overexposures to chemical and/or physical stressors shall directly be investigated by EHS.

  • For other incidents where additional follow-up is appropriate, EHS will review submitted information to ensure that adequate corrective actions have been identified and implemented.

Hazard Correction

The Company is committed to correcting unsafe or unhealthy work conditions in a timely manner, based on the severity of hazards.

Correction of Hazards Schedule

Hazards within the workplace shall be corrected as follows:

  • When observed or discovered; or

  • When an imminent hazard exists that cannot be immediately abated without endangering employee(s) and/or property:

    • All exposed personnel shall be removed from the area, except those necessary to correct the existing condition.

    • Employees required to correct the hazardous condition shall be provided with necessary safeguards, including adequate personal protective equipment (PPE).

Resources

Unsafe conditions that cannot be corrected with resources available to the manager or supervisor must be reported to the next level of management, department lead, or to the Company’s Environmental Health and Safety (EHS) department. Resources to correct hazards include the following:

  • If the correction 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, other resources from the Company shall be sought.

Recordkeeping

As corrective actions are implemented, the effort shall be documented and maintain for at least one (1) 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 safe 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; and

  • 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

  • New hire orientation is provided by the Company’s Human Resources (HR) department to all new employees; includes information regarding the Company’s health and safety:

    • Policies and practices;

    • Responsibilities;

    • Employee rights;

    • Services; and

    • Expectations for further training.

Tier Two: Hazard-Specific Training

  • Hazard-specific training is provided by the Company’s Environmental Health and Safety (EHS), or other appropriate departments, to employees who may encounter workplace hazards; topics include:

    • Emergency response and evacuation;

    • Ergonomics;

    • Hazardous communication; and

    • Forklift safety.

Tier Three: Job-Specific Training

  • Job-specific training is provided by department leads, managers, or supervisors as appropriate.

  • Training consists of information specific to the hazards and equipment; it can be communicated by:

    • Safety data sheets (SDS) and material safety data sheets (MSDS);

    • Pamphlets and/or booklets;

    • Safety meetings; and

    • Postings.

  • The Company’s Environmental Health and Safety (EHS) department may randomly review tier three training to confirm adequacy and consistency.

Training Schedule

Training shall be provided to all employees when:

  • The Injury and Illness Prevention Program (IIPP) was first established;

  • A new employee is hired;

  • Employees are given new job assignments, for which training has not been previously conducted;

  • A new substance, process, procedure, or equipment is introduced to the workplace and that represents a new hazard;

  • A new or previously unrecognized hazard is discovered; and

  • An employee is promoted to a manager or supervisor role.

    • So they can be familiarized with health and safety hazards that their employees may be exposed too.

Training Resources from Environmental Health and Safety (EHS)

  • The Company’s Environmental Health and Safety (EHS) department can assists employees, managers or supervisors, department leads, and other departments in preparing, providing, and maintaining health and safety training for employees; includes training for:

    • Injury and Illness Prevention;

    • Workspace safety; and

    • Personal protective equipment (PPE) use.

  • EHS is available to assist supervisors and managers, along with department leads, in implementing health and safety training programs for their own work environments.

Recordkeeping

  • Documentation of health and safety training for each employee shall include:

    • Employee name, identification number, or other identifier method;

    • Training date;

    • Type of training; and

    • Training provider.

  • Documentation shall be maintained for at least three (3) years for each employee after their employment is terminated.

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