Dow Chemical 2009 Annual Report Download - page 100

Table of Contents
Detailed information on Dow’s performance regarding environmental matters and goals can be found online on Dow’s Sustainability webpage at
www.dow.com.
Chemical Security
Public and political attention continues to be placed on the protection of critical infrastructure, including the chemical industry, from security threats. Terrorist
attacks and natural disasters have increased concern about the security of chemical production and distribution. Many, including Dow and the American
Chemistry Council, have called for uniform risk-based and performance-based national standards for securing the U.S. chemical industry. The Maritime
Transportation Security Act (“MTSA”) of 2002 and its regulations further set forth risk-based and performance-based standards that must be met at U.S.
Coast Guard-regulated facilities. U.S. Chemical Plant Security legislation was passed in 2006 and the Department of Homeland Security (“DHS”) is now
implementing the regulations known as the Chemical Facility Anti-Terrorism Standards. The Company is complying with the requirements of the Rail
Transportation Security Rule issued by the U.S. Transportation Security Administration (“TSA”). Dow continues to support uniform risk-based national
standards for securing the chemical industry.
The focus on security is not new to Dow. A comprehensive, multi-level security plan for the Company has been maintained since 1988. This plan, which
has been activated in response to significant world and national events since then, is reviewed on an annual basis. Dow continues to improve its security
plans, placing emphasis on the safety of Dow communities and people by being prepared to meet risks at any level and to address both internal and external
identifiable risks. Dow’s security plans also are developed to avert interruptions of normal business work operations that could materially and adversely affect
the Company’s results of operations, liquidity and financial condition.
Dow played a key role in the development and implementation of the American Chemistry Council’s Responsible Care® Security Code, which requires
that all aspects of security – including facility, transportation and cyberspace – be assessed and gaps addressed. Through the Company’s global
implementation of the Security Code, Dow has permanently heightened the level of security – not just in the United States, but worldwide. Dow employs
several hundred employees and contractors in its Emergency Services and Security department worldwide. In addition, Dow has committed approximately
$200 million in capital over a ten-year period for plant security, supply chain and cyberspace security enhancements, regulatory compliance and response
capabilities as well as other components of Dow’s security program. These costs are not considered material to the Company’s consolidated financial
statements.
Through the implementation of the Security Code, including voluntary security enhancements and upgrades made since 2002, Dow is well-positioned to
comply with the new U.S. chemical facility regulations and other regulatory security frameworks. In addition, Dow was the first chemical company to receive
coverage under the Support Anti-terrorism by Fostering Effective Technologies Act (“SAFETY Act”) from the DHS in 2007 for the Company’s MTSA
regulated sites, and the first to receive coverage under SAFETY Act in 2008 for the Company’s Rail Transportation Security Services. This unprecedented
certification helps validate Dow’s efforts and provides additional liability coverage in the event of a terrorist attack.
Dow continues to work collaboratively across the supply chain on Responsible Care®, Supply Chain Design, Emergency Preparedness, Shipment
Visibility and transportation of hazardous materials. Dow is cooperating with public and private entities to lead the implementation of advanced tank car
design, and track and trace technologies. Further, Dow’s Distribution Risk Review process that has been in place for decades was expanded to address
potential threats in all modes of transportation across the Company’s supply chain. To reduce vulnerabilities, Dow maintains security measures that meet or
exceed regulatory and industry security standards in all areas in which the Company operates.
Dow continually works to strengthen partnerships with local responders, law enforcement and security agencies, and to enhance confidence in the
integrity of the Company’s security and risk management program, as well as strengthen its preparedness and response capabilities. Dow also works closely
with its supply chain partners and strives to educate lawmakers, regulators and communities about the Company’s resolve and actions to date that mitigate
security and crisis threats.
70