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By Kevin Munn
PACIA members participate in Community Advisory Panels for face-to-face discussions with other stakeholders.17, 18 At present, PACIA reports that 40 per cent of its members participate in CAPs, which meet four to seven times per year. The number of CAPs has increased steadily, from two in 1988 to 25 in mid-1996; five more are in formation. A positive element of the CAP activities is the feedback that is gathered from them by PACIA. A survey of panel members in late 1995 (nine of 24 panels responded) indicate that the CAPs give a moderate-to-strong approval rating in response to questions like; "The Consultation Panel is an effective way to have our concerns heard" (2.8 rating, with 1 = strongly agree and 10 = strongly disagree); "We get good cooperation from the companies involved" (2.9 rating); "Companies listen to our concerns and act upon them" (3.7 rating); and "There is a keen and ongoing general community interest in the activities of the panel" (3.9 rating). Comments gathered by this same survey on areas needing improvement revealed no comments which would indicate that any participants were dissatisfied with the CAP process.19
The above survey covered a relatively small group of individuals (54 responses), but is a credible and encouraging development in that it uses for evaluation data gathered from the Responsible Care programme itself. Another relevant survey was conducted in 1992, and canvassed 800 people in five major Australian cities.20 The key conclusions were: 90 per cent of the people knew little or nothing about the chemical industry, 75 per cent were concerned about its operations, 49 per cent said the industry had improved ESH performance in the last three years (but only because it was forced to), and generally that the industry was dangerous, polluting and dishonest. A follow-on survey in 1994 revealed that public opinions of the industry had actually worsened in almost all areas. The disparity of these results with the opinions of approval from the CAP survey highlight one of the major and continuing challenges to the programme everywhere: how to have demonstrations of responsible industry behaviour recognized beyond the CAPs in the wider community.
PACIA reported some advanced methods for approaching these elusive ends.21 It reported that, in 1993, 15 performance indicators of interest to the community had been identified by the CAP and the National Community Advisory Panel (NCAP -- described below). Seven of these indicators formed the basis for the CAP survey detailed above. An additional four items are to be added to the next survey.
Additional performance indicators cited come from PACIA members self-assessments, and indicate that between 40-60 per cent of those in the programme consider themselves to be in compliance with the COP (not counting the product stewardship COP, which has a lower compliance rating). Other performance indicators, such as transportation incidents, workplace accidents and wastes released to the environment were also reported in the literature. A valuable measure of process safety is seen in the PACIA-developed indicator of "plant incidents", which appears to be a measure developed around the Responsible Care programme and which tracks facility incidents which result in a set amount of damage, the release of significant or reportable amounts of dangerous goods or a fatality or lost-time injury.
The Australian programme also includes a National Community Advisory Panel (NCAP), a group of 13 opinion leaders including concerned citizens, OSH specialists, environmentalists, academics, trade unionists and emergency response personnel. It meets quarterly and advises PACIA on its programme. The NCAP noted in its 1994-95 report some revealing practices:
1. Companies continuing to sell chemicals when some research results pointed to potential detrimental effects.
2. Companies continuing to produce and sell to developing countries chemicals whose use is banned or restricted elsewhere.
3. Communities who observe unusual effects of chemicals on their physical environments or their human inhabitants.
NCAP gives a qualified approval to the PACIA programme, and notes that the future will see more, rather than fewer challenges.
Lastly, the external verification activities at PACIA should give the programme a significant credibility boost.22 These activities began in 1994. The results of the verifiers have so far largely concurred with those of the self evaluations. One of three external agencies performs the verifications. Audited sites are "encouraged" to include observers on the verification teams from community groups, local councils and regulatory agencies. Depending on the degree of inclusion of these groups in the external verifications, this lack of a mandatory requirement for public participation may undercut the credibility-boosting potential of the audits. Verification team reports are not required to be made public.
Country/association: United Kingdom/CIA -- Chemical Industries Association
Year Responsible Care adopted: 1989
Condition of membership?: Yes
The indicators, while not conclusive, do show notable and continued improvements in energy consumption (down 10 per cent over the period 1990-95), in discharges of Red List substances (down 89 per cent over the period 1990-95), number of transport incidents (down one-third over the same period), in the number of CIA-member sites which currently have active links with their local communities (75 per cent in 1995) and in the number of sites which have formal or certified management systems for health and safety and for environment (81 per cent and 61 per cent, respectively). In this last category the statement "has a formal or certified system" means that the procedure for the operation of processes to a specified standard are defined and fully documented.
Encouraging trends are also seen in lost-time accidents for employees of members and for contractors.
CIA noted the existence of an "Opinion Panel"25 but details of its function and influence were not described, and no statements from the Panel were presented in the programme documents.
External verification of the management systems is considered by many to be a fundamental requirement for a credible Responsible Care programme. CIA is currently experimenting with methods of third-party verifications, though the approach has thus far been rejected by the membership as a general requirement. Pilot trials were scheduled for late 1996 at nine member locations, and the results will be presented to CIA members as they consider whether to adopt verification as a standard part of the UK programme.26
Country/association: France/UIC -- Union des Industries Chimiques (Union of Chemical Industries)
Year Responsible Care adopted: 1990
Condition of membership?: No (participation level: not reported)
Perhaps the most significant omission is the lack of any codes of practice. Some other programmes which have relatively broad general statements in the GPs, tend to compensate through robust COP (e.g. CCPA). Without COP, however, understandable doubts will exist as to the methods used by firms to achieve the goals of the GPs.
The absence of COPs might also make it difficult for UIC to gauge its members' progress in implementing their programmes. A 1996 investigation,30 based on a self-assessment questionnaire from UIC to its members, concluded that most of its members now have in place a programme to fulfil the nine GPs. No feedback was evident, however, in the form of statistics (for example, the past/current number of community advisory panels) or other data such as case histories, incident reports showing a Responsible Care programme providing benefit, public opinion polls, community or government comments, etc. The absence of COP also raises questions as to what eventual mechanisms might be employed by UIC or outside verifiers to certify compliance with the Responsible Care programme: external verification has already been identified as a key factor towards programme credibility.
UIC does not have a national advisory panel.
Performance indicators used by UIC do not appear to be derived from the development of its Responsible Care efforts. Those cited to show progress include workplace accidents and emissions of selected pollutants. Most statistics were collected from government sources, and were required reporting prior to the inception of the French Responsible Care programme. Accident rates and emissions of most pollutants have declined since Responsible Care was initiated by UIC.
Country/association: Japan/JCIA -- Japan Chemical Industry Association
Year Responsible Care adopted: 1990
Condition of membership?: Yes (?) (participation level: apparently 100 per cent)
-- To develop safe products and process technologies by determining the impact of such ... at the research and development stages;
-- To operate plants and facilities safely so as to ensure the protection of the environment and the health and safety of employees and the public ...
However, the sole reference to interaction with other stakeholder groups is relatively weak:
-- To be sensitive to the concerns of government officials and the public regarding our products and operations and to work toward improved communications.
-- the establishment of Responsible Care programmes and reporting progress;
-- reporting on chemical emissions inventories, which calls for emission inventories to be made for a considerable number of chemicals -- 259 in total -- well above the legally prescribed requirements;
-- conducting internal Responsible Care audits;
-- transportation safety management;
-- waste management; and
-- comprehensive safety management of chemical products transactions.
The guidelines were issued mainly in 1995, and only after this date could the industry be said to be applying homogeneous programme measures and procedures. Coinciding with the issuance of the code and guidelines, JCIA formed a Japan Responsible Care Council (JRCC) to promote the implementation of the programme more actively.
The 1995 Annual Report32 from JRCC cites a high level of completion (based on member self-assessments) for the general management aspects of the programme, such as assigning internal responsibilities under the programme, familiarizing employees with it, drawing up annual and long-term programme goals, publishing an annual report, etc.
The more detailed elements of the JCIA programme are contained in the guidelines which, while they are useful for the members who are setting up their programmes, do not provide the same level of clarity as to specific required management practices as do the more developed COPs of other national associations (e.g. CCPA, PACIA). Some of the guidelines call for expanding on an existing legal framework, such as labelling practices during the transport of chemicals.
Fulfilment of the guideline elements is less complete than for the general management practices (members reported essentially full compliance with the programme establishment and reporting guideline). For example, for the categories inquiring to what extent ESH was considered in R&D, new product development, technology transfer and international operations, fully 70+ per cent of all members declined to respond to these topics; less than 20 per cent assessed their progress as meeting or exceeding the guideline requirements. (Note: Non-response could also arise from a company having no activity in the subject area, thus signifying "not applicable").
One of the more revealing assessment responses is for the public interaction category. When asked if companies had developed social dialogue (presumably with local communities and other stakeholders), just over 25 per cent affirmed that they had done this to the guidance requirements -- 60 per cent did not respond to this item. This indicates the extension, in practice, of the weak call in the GPs for proactive public involvement.
Practices where one would expect to see more development, such as meeting all requirements for supplying hazards information during operations, transport or disposal, or for establishing and maintaining process safety measures, were reported to have a higher rate of completion, with 50-70 per cent of the members assessing their progress as sufficient to meet or exceed the guideline. In general, the guidelines for which JCIA members self-assessed a high degree of completion are those for which a legal framework predated the programme.
JRCC supplies JCIA members with a rather broad check-list for self-assessment.33 Questions like: "Are the manuals and training for operational accident responses sufficient?" (control of factory operations check-list) and "Does the company pay attention to safety and environment when developing new products and new projects?" (safety in development and new products check-list) are too general to allow for an objective quantification of progress. Sceptical stakeholders could remain unconvinced and in disagreement with the corporate self-assessment of achievements.
The JCIA programme, on a whole, appears to be a framework capable of providing sufficient guidance to its members to enable them to build adequate Responsible Care programmes. But in the author's opinion considerable development remains to be done before the JCIA programme could be used to provide guidance, demonstrate industry leadership and initiative and gather meaningful results on a national scale.
Lack of sufficient detail in the guidelines and the JRCC check-list will make third-party assessment (or defensible JRCC assessment, for that matter) as well as any eventual verification difficult and easily contested. This shortcoming has also been noted in a number of other national programmes. Additionally, the lack of public involvement in the programme, as seen by the low level of public interaction, may be a barrier to successful and credible recognition of legitimate programme achievements. The ICCA reports that JCIA does sponsor a group of experts which provides input on ESH issues;34 neither JCIA nor ICCA provided details of the panel's makeup or its assessment of the Japanese programme.
JCIA's programme did not report the use of performance indicators to illustrate progress.
Country/association: Sweden/KS -- Kemikontoret Service AB (Association of Swedish Chemical Industries)
Year Responsible Care adopted: 1991
Condition of membership?: No (participation level: 123 of 161 members)
16 PACIA, Responsible Care management practice summary, Aug. 1994.
17 M. MacKeller, "Community Views -- Their impact on Australia's chemical industry", presented to the XXI Medichem Congress, 18-21 Oct. 1994, Melbourne.
18 PACIA, Local community advisory panels continue to grow in Australia, press release, 26 Feb. 1996.
19 op. cit.
20 M. MacKeller, "Community views -- Their impact on Australia's chemical industry", presented to the XXI Medichem Congress, 18-21 Oct. 1994, Melbourne.
21 PACIA, Responsible Care News, Jan. 1996.
22 PACIA, memo. from J. Smith (PACIA) to Responsible Care coordinators, 26. Oct. 1994.
23 CIA, Responsible Care -- Improving health, safety and environmental performance in the chemical industry, 1996.
24 CIA, The UK indicators of performance, 1990-1995, 1996.
25 S. Aaron, "Responsible Care and integrated management systems", paper, 1996.
26 CIA, "CIA verification of key elements of Responsible Care", communiqué to CIA members, Oct. 1996.
27 UIC, Engagement de Progrès -- Bilan Exercice 1995.
28 J. Smith, Chemical industry programs -- Community, safety and environment, PCIA, 1996.
29 CMA, Responsible Care progress report, 1995-1996, 1996.
30 UIC, L'Engagement de Progrès de L'Industrie Chemique Française, press release, 23 Oct. 1996.
31 JRCC, Responsible Care in Japan -- Ensuring safety and health and protecting the environment throughout the product life cycle of chemical substances, date unknown, Tokyo.
32 JRCC, 1995 Annual Report on Responsible Care.
33 Communiqué from R. Kawano (ILO) to K. Munn, 22 Jan. 1997.
