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To highlight the achievement, the agency recently issued a case study -- Contractor Safety Case Study: Texas Operations Contractor Alliance for Safety at Dow Facility in Freeport, Texas. The report describes how Dow and 15 contractor companies formed the Texas Operations Contractor Alliance for Safety. The organization consisted of senior managers from Dow's Texas operations and from its on-site contractors who could authorize implementing safety and health management systems within their own companies.

"Through the alliance program and its other cooperative programs, OSHA has developed a growing collection of success stories and case studies that demonstrate the value of safety and health management systems," said Edwin G. Foulke Jr., assistant secretary of labor for the Occupational Safety and Health Administration. "This case study effectively demonstrates how safety and health management systems can be successful if organizations take proactive steps to implement and encourage their use."

Contractor safety became a concern. Dow began to reach out to the contractor firms working at its Texas Operations in the early 1990s in an effort to improve their safety performances. According to officials, the discussions between the management team from Texas Operations and the safety managers from the individual contractor firms were not very effective. The contractor safety managers had difficulty convincing their respective organizations to make changes to their safety and health programs largely because it meant more work for the management teams in their organizations.

As a result, OSHA said the efforts to improve contractor safety remained largely Dow-driven. After experiencing repeated hesitation on the part of the contractors, Dow managers concluded that future safety discussions between Dow and the contractors would be productive only when senior, management-level people from the firms were involved.

In 1994, managers at the Dow corporate office announced the goal of reducing the recordable injury rate (for all Dow and contractor employees) by 90 percent at all company work sites. According to officials, the need to have top-level contractor involvement combined with the need to meet Dow's corporate goal led to the formation of a new and unique safety alliance between Texas Operations and its service providers.

Texas Operations implements changes. In 1995, Texas Operations management began implementing changes in its safety and health program for contractors. The first step was to organize twice monthly contractor safety meetings. The Texas Operations Contractor Alliance for Safety was formed with 15 contractor companies.

Officials said the effort produced improvements almost immediately. In 1995, the Texas Operations recordable rate was 3.31 -- the number of injuries per 200,000 worked hours. By 1996, the rate had dropped to 1.85. According to Dow, convening the managers responsible for the financial and human resources of the contractor companies resulted in the start of positive changes.

According to OSHA, TOCAS worked and still works to identify and articulate the safety-related needs of its broad spectrum of contractor companies and partners with Texas Operations to improve contractor safety performance. TOCAS provides all contractor companies doing business with Texas Operations with a forum for sharing the purposes, expectations, strategies, incentives and results of the community of contractors working at the site. The agency said the contractor representatives to TOCAS are the decision-makers that can commit their companies to safety programs, employee involvement and actions. The companies' safety contacts form another group that works to improve safety within the plants.

Through the program, officials said Texas Operations management provides the data on a safety issue to TOCAS and asks its members to find solutions and establish priorities. OSHA said all contractor companies providing labor services to Texas Operations are eligible to be associated with TOCAS. In return, members are asked to provide ongoing commitment to the goals and philosophy of TOCAS. As a result, OSHA said the expectation on the part of Dow is that safety performance within Texas Operations will continue to improve. Officials said the basic elements of TOCAS are similar to the critical elements of an effective safety and health management system -- management commitment and employee involvement; work site analysis; hazard prevention and control; and training for employees, supervisors and managers.

Program making an impact. The number of contractor companies involved in TOCAS has grown from 15 in 1995, to 23 in 1996, to 85 in 2008. Each of the approximately 12,000 contractor employees has a badge, and each badge holder has successfully completed a background check, drug test and training.

From the time that TOCAS began in 1995 to 2007, the OSHA recordable rate for contractors has improved 95 percent overall. The program has been so successful that similar organizations are now in place at Dow facilities in Texas (Seadrift, Texas City and Houston) and Louisiana (Baton Rouge and New Orleans).

In part, OSHA said TOCAS is successful because it gives contractors control over their own programs. Officials said contractors can implement the rules, standards and processes that address their and Dow's largest issues and track their performance to see what is successful. According to the agency, the Texas Operations model demonstrates that contractors can and do learn from one another. Through sharing their policies and experiences, contractors leverage expertise and solutions, officials said.

November 4, 2008

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