Maintenance Head Protection Policy

INACTIVE POLICY — PENDING DEPARTMENT REVIEW

Introduction

As part of its continued commitment to the health and wellness of employees, independent contractors, and other visitors, Dow Aero, LLC (“Company”) has developed this policy to protect individuals from potential hazards that exists when within designated areas of the maintenance shop that require head protection.

Scope

This policy applies to any authorized individual performing a task within a designated area of the maintenance shop where head protection is required. This policy also applies to any individual permitted to be within a designated area of the maintenance shop where head protection is required for any other capacity (e.g. including observation, inspection, touring, etc.

Policy

It is the policy of the Company that head protection areas will be marked on appropriate flooring surfaces that has been taped or painted with a striped orange and black design (see Figure 1). All head protection markings shall remain visible and identifiable. This includes clearing excessive dirt and debris routinely and not storing or parking any materials or equipment on head protection markings. Sections of the head protection markings that are damaged or extremely faded shall be replaced or repainted as soon as possible; notify management or Environmental Health & Safety (EH&S) for assistance.

Figure 1 - Appearance May Differ

Figure 1 - Appearance May Differ

The policy of the Company also includes that head protection is to be used by an individual that works within a designated head protection area, with exception too:

  • Any period of industrial inactivity in the designated head protection area.

    • Some examples of what is considered a period of industrial inactivity include break and meal periods, or periods outside of shifts where no operational tasks and facility maintenance are occurring.

The Company reasonably provides individuals with all appropriate head protection. The Company shall provide individuals working in the maintenance shop with, protective helmets (Hard Hats) that conforms to the ANSI Standard for Industrial Head Protection, ANSI Z89.1 and shall reasonably offer replacements free of charge as needed. Maintenance areas or tasks that require Protective Helmets or Bump Caps, shall be provided by the Company, and may either be assigned to an appropriate individual(s) and/or provided near areas or tasks where required. Employees shall remain aware of all Personal Protective Equipment (PPE) required in their work area(s) and prior to performing job functions, whether by consulting applicable Company policies or procedures, manufacture manuals, or Safety Data Sheets (SDS).

When necessary, headgear must be properly fitted for the user. Poor fit will compromise the protection that would ordinarily be afforded by the device. Do not modify headgear from the manufacturer’s original design or use optional equipment that has not been approved by the manufacturer. Handle the protective headgear with care. Do not carry or wear objects inside of a hardhat between the suspension and the shell. Please note that an object with metal parts placed under a hard hat may also diminish the dielectric (electrical conducting) protection. Remember bump caps is only use when protection is needed from minor head bumps and lacerations. Bump caps are not designed to protect against falling or flying objects and are not ANSI-approved.

Should any questions, concerns about head protection equipment issues arise please contact a direct superior, the manager overseeing this department (currently Dean Meloni, Director of Production), Environmental Health & Safety (EH&S) personnel, and/or Human Resources personnel. Likewise, you may reach out to any of the individuals or departments mentioned above in the event you are uncomfortable or unable to maintain compliance with this policy; reasonable accommodation shall be examined and implemented as practicable.

Acceptance

This record was developed and is maintained by Environmental Health & Safety (EH&S). Policies outline within are approved and enforced by Operations Management.

Change Log

PENDING - Version 1

Policy approved by Director of Production (Department Lead of Maintenance) and deployed.