Dow Gulf Coast Dow Gulf Coast PipelinePipeline

Contractor Background Contractor Background Check RequirementsCheck Requirements

Contractor Background Contractor Background Checks: Dow Gulf Coast Checks: Dow Gulf Coast

PipelinePipeline• September 11, 2001 brought about September 11, 2001 brought about

many changes for industry in the U.S.many changes for industry in the U.S.• New Government Regulations and New Government Regulations and

Guidelines for Chemical IndustryGuidelines for Chemical Industry• Extensive Security Vulnerability Extensive Security Vulnerability

Assessments at Dow indicated a need Assessments at Dow indicated a need to enhance background checks of all to enhance background checks of all Dow employees non-Dow service Dow employees non-Dow service providersproviders

Background Check Background Check Requirements for Non-Dow Requirements for Non-Dow

(Contract) Employees(Contract) Employees• Background check is required of all non-Dow individuals who Background check is required of all non-Dow individuals who

request a permanent badge request a permanent badge – Background check service set up through Area Reciprocal Safety Background check service set up through Area Reciprocal Safety

Councils (ie. HIRECHECK Basic Package)Councils (ie. HIRECHECK Basic Package)• Social Security Verification (SSN) Social Security Verification (SSN) • Motor Vehicle Registration Motor Vehicle Registration • <=3 County Criminals (Felony Convictions within 7 year period) <=3 County Criminals (Felony Convictions within 7 year period)

– Patriot Act Check (Set up through Area Reciprocal Safety Council) Patriot Act Check (Set up through Area Reciprocal Safety Council) – Verification of Citizenship Verification of Citizenship

• Social Security Number or an Appropriate Work VISA if not a U.S. Citizen Social Security Number or an Appropriate Work VISA if not a U.S. Citizen • If no Social Security Number ES&S will contact appropriate personnel in If no Social Security Number ES&S will contact appropriate personnel in

Dow’s Midland, Michigan headquarters to get clearanceDow’s Midland, Michigan headquarters to get clearance• Note: Background checks for GCPL contractors that will be Note: Background checks for GCPL contractors that will be

working in one of the Dow Louisiana Large Sites must be working in one of the Dow Louisiana Large Sites must be obtained through a specified company- you will need to go obtained through a specified company- you will need to go through the Louisiana Operations background check and through the Louisiana Operations background check and badging process.badging process.

Background Screen Background Screen Verification FormVerification Form

• ““Background Screen Verification Form” must Background Screen Verification Form” must be filled out and signed by a Contractor be filled out and signed by a Contractor Company Representative and delivered to Dow Company Representative and delivered to Dow ES&S ES&S

• Verification of Criminal History Check – Last 7 Verification of Criminal History Check – Last 7 years for convictions of any crimes involving years for convictions of any crimes involving theft, destruction of property, violence or drugs theft, destruction of property, violence or drugs

• Check of Citizenship Check of Citizenship • Verification of Social Security Number (If there Verification of Social Security Number (If there

are any discrepancies, exceptions may be are any discrepancies, exceptions may be made on a case by case basis by the ES&S made on a case by case basis by the ES&S Leader)Leader)

Hire-In Slip Badge Request Hire-In Slip Badge Request FormForm

– Contractor Company Representative Signs Contractor Company Representative Signs Page One of Form as a Written Confirmation Page One of Form as a Written Confirmation that Requirements Have Been Met that Requirements Have Been Met

– Social Security Number Verification Social Security Number Verification – Background Screen Completed and Cleared Background Screen Completed and Cleared – Appropriate Safety Training Completed Appropriate Safety Training Completed – Pre-Access Drug Screen Requirements Pre-Access Drug Screen Requirements

Completed Completed – Has demonstrated oral and comprehension Has demonstrated oral and comprehension

abilities of English language abilities of English language – Answer question – Is this an Ex-Dow Answer question – Is this an Ex-Dow

Employee?Employee?

Hire-In Slip Badge Request Hire-In Slip Badge Request FormForm

– Contractor Employee Signs Page Two of Form Contractor Employee Signs Page Two of Form Confirming Information Listed is Correct Confirming Information Listed is Correct

– Personal Information ( Date of birth, height, weight, Personal Information ( Date of birth, height, weight, drivers license number, etc.) drivers license number, etc.)

– Former employee of contractor company working Former employee of contractor company working on site? on site?

– Worked in Dow Freeport Site within last 6 months? Worked in Dow Freeport Site within last 6 months? – What company did you work for? What company did you work for? – Have you ever been convicted Have you ever been convicted For Any Law For Any Law

ViolationsViolations other than minor traffic in the last 10 other than minor traffic in the last 10 years?years?

Estimated Cost and Time Estimated Cost and Time Frame of Background Frame of Background

CheckCheck• HIRECHECK Basic Package and Patriot Act HIRECHECK Basic Package and Patriot Act

Check - $57.00 (normally takes about 1 to 2 Check - $57.00 (normally takes about 1 to 2 days)days)

• Area Reciprocal Contractors’ Safety Council: Area Reciprocal Contractors’ Safety Council: – Sets up an account with HIRECHECK or other Sets up an account with HIRECHECK or other

approved serviceapproved service– Background Check Service bills Safety Council Background Check Service bills Safety Council – Safety Council bills Contractor CompaniesSafety Council bills Contractor Companies

• Note: Background checks for GCPL contractors Note: Background checks for GCPL contractors that will be working in one of the Dow Louisiana that will be working in one of the Dow Louisiana Large Sites must be obtained through a specified Large Sites must be obtained through a specified company- you will need to go through the company- you will need to go through the Louisiana Operations background check and Louisiana Operations background check and badging process.badging process.

Questions and AnswersQuestions and Answers• If a person changes contractor companies If a person changes contractor companies

and had a background screen with his or and had a background screen with his or her previous company, does the person her previous company, does the person need to have another background screen?need to have another background screen?

• Yes. One of the benefits of coordinating the Yes. One of the benefits of coordinating the background screens through a centralized background screens through a centralized organization or agency, such as a contractor organization or agency, such as a contractor safety council, is that the background safety council, is that the background screenings can be consolidated. If a screenings can be consolidated. If a background screen was conducted within the background screen was conducted within the last twelve (12) months prior to requesting the last twelve (12) months prior to requesting the new entry badge, the previous screening can new entry badge, the previous screening can be used and a new background screen is not be used and a new background screen is not required.required.

Questions and Answers Questions and Answers (cont.) (cont.)

• How often will the background How often will the background screens be conducted?screens be conducted?

• Background screens are required to be Background screens are required to be updated every three (3) years if a updated every three (3) years if a person stays with the same non-Dow person stays with the same non-Dow company, updated or completed when company, updated or completed when the person changes companies and the person changes companies and requests a new Dow GCPL badge requests a new Dow GCPL badge (unless a background screen has been (unless a background screen has been conducted within the previous 12 conducted within the previous 12 months)months)

Questions and Answers Questions and Answers (cont.) (cont.)

• What happens if a person is convicted of What happens if a person is convicted of a crime after the background screening a crime after the background screening has been conducted?has been conducted?

• Companies should frequently review the Companies should frequently review the performance of their employees (attendance, performance of their employees (attendance, daily performance, etc.) and investigate any daily performance, etc.) and investigate any reports of possible activity that could reports of possible activity that could jeopardize his or her ability to work on the jeopardize his or her ability to work on the Dow site. Any confirmed criminal conviction Dow site. Any confirmed criminal conviction should be reported and discussed with Dow’s should be reported and discussed with Dow’s site ES&S for appropriate action. site ES&S for appropriate action.

Questions and Answers (cont.) Questions and Answers (cont.)

• What if a person is convicted and What if a person is convicted and currently on parole for that currently on parole for that conviction?conviction?

• Convictions related to theft, violence Convictions related to theft, violence or drugs could jeopardize a person’s or drugs could jeopardize a person’s ability to work on the Dow site. Any ability to work on the Dow site. Any confirmed criminal conviction should confirmed criminal conviction should be reported and discussed with Dow’s be reported and discussed with Dow’s site ES&S for appropriate actionsite ES&S for appropriate action

Questions and Answers Questions and Answers (cont.) (cont.)

• When the background screening When the background screening process starts, if a company knows of process starts, if a company knows of an issue with a currently badged an issue with a currently badged contractor company employee, i.e. contractor company employee, i.e. false Social Security Number, false Social Security Number, significant criminal history, etc., significant criminal history, etc., what will happen?what will happen?

• The contractor company must The contractor company must immediately contact Dow ES&S for immediately contact Dow ES&S for consultationconsultation