Responsible Care and related voluntary initiatives - 3

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Responsible Care and related voluntary initiatives to improve enterprise performance on health, safety and environment in the chemical industry

By Kevin Munn

Part 3

2.2.1 Programme structure

The forces which catalysed the creation of the Responsible Care programme have in large part also defined it. As an example, the concerns of governments and the general public over the safety of operating chemical facilities are reflected in the programme's paradigms through broad ethical statements which refer to the responsibility of a firm for the safety of the persons near its facilities. In this specific topic, the programme goes further than just a statement of principle, and in the more advanced programmes details suggested practices for how a firm might go about ensuring that a "safe" environment is created, confirmed and maintained, and how this fact can be communicated to the local communities.

This structure of guiding principles (GPs) and codes of practice (COPs) is the basic approach taken by most Responsible Care programmes: associations' members state what they intend to do with the former; and details of how they should accomplish these goals are in the latter. There are now 40 national chemical industry associations which have adopted Responsible Care, and this principle-practice design is present in almost all the programmes reviewed by the author.

In general, the guiding principles refer to the responsibility of the industry to conduct its operations so as to minimize the negative impact (and risk of impact) on the workers, environment and all other persons which these operations may affect. Considerable variations exist in the strength and scope of the GPs, but these generally can be viewed as benchmark statements defining the fundamental ethical responsibilities and operational philosophies of the industry. An example of GPs which include elements seen in many of the Responsible Care programmes is that of Australia (figure 1). The GPs entail or infer (through specific statements) pollution prevention, emergency planning, a proactive attitude towards the public and government and the minimization of risk (to the environment, employees and the public) from all existing or proposed operations and products.

The GPs are the philosophical principles of the chemical industry under Responsible Care, and they form the framework for activities within individual national association and corporate programmes. There are considerable variations in the GPs of the individual national chemical associations' texts, as can be seen in Appendix A, where brief outlines of the individual programmes are presented (based on the contributions from these associations). An analysis of the national programmes is also presented. An overview of individual association elements relative to one another can be seen in table 1, where it is indicated which elements, within the range of those specifically mentioned by the Responsible Care programmes reviewed, are included in the various national associations' programmes.

Many national associations now require, as a condition of membership, that their members subscribe to these philosophical tenets. Whether a condition of membership or not, when a firm commits itself to the programme, the chief executive officer (or the highest-ranking regional representative) must sign an affirmation that the GPs will be adhered to in all company operations (this is typically applicable only to the company's domestic operations, though some associations -- notably CCPA -- require application to international operations as well). Fulfilment of this requirement for all association members clearly is evidence of a serious and concerted effort on the part of a nation's chemical industry to make Responsible Care the credible focal point of the industry's environment, safety and health (ESH) performance.

Being broad and encompassing statements of principle, the GPs do not provide a suitable framework for judging the level of progress attained by a firm in giving effect to the individual principles. For this, quantifiable requirements need to be detailed. Responsible Care's answer here is the codes of practice. These are the definable operational activities and management practices which are deemed necessary for a firm to arrive at a level of sufficient performance, vis-à-vis the broad requirements of the GPs, such that one can state with some confidence that Responsible Care is being successfully implemented. Complying with the demands of the COP is the most difficult and time-consuming element of Responsible Care.

Within the submitted descriptions for the national Responsible Care programmes, the COP vary significantly. There is one large group of associations where one can see a recurrent pattern in their COPs; this is probably attributable to the efforts of the chemical industry to promote Responsible Care internationally, and will be discussed later. In some nations, there are no COP, and the GPs form the basis for corporate actions under Responsible Care. Many other countries are still developing their COP, and have issued only some of the foreseen codes. These include the majority of nations which have adopted Responsible Care in recent years. Yet other associations have no COP, but have issued "guidance" for their members (or a mix of COP and guidance). These guidance measures appear to be more detailed than the GPs, but also less rigorous in their requirements for specific actions or for attaining defined goals than the COP. Again, details on the COP/guidance for specific associations can be found in Appendix A.

As for the general form and content of the COP, they are normally concerned with plant operations, transportation and distribution functions, pollution prevention measures, emergency prevention and response, occupational health and safety, community/public relations and "product stewardship". These areas are detailed as to their goals below, and table 2 briefly summarizes the content and current status (of completion) for the individual industry associations' COP. As many associations which responded to the questionnaire for this study did not submit detailed text on their COP, qualitative judgements for some COP were difficult. These cases are indicated as incomplete, and it should be pointed out that an "incomplete" denotation signifies that some form of code does exist, and that it was simply not possible to quantify how comprehensive it is. Only in cases where it was clear that no COP existed (and no evidence was found that one was under development) was this indicated.

Table 1. Topics addressed by the guiding principles of national Responsible Care programmes

*** -- indicates a strong and direct commitment to this topic; ** -- indicates a weak commitment or indirect reference to this topic; o -- indicates that this topic is not mentioned in the guiding principles.

Canada CCPA United States CMA Australia PACIA United Kingdom CIA France UIC Sweden KS Belgium ICB Hungary HCIA Korea KPIA India ICMA Portugal APEQ Zimbabwe INCHEM Japan JCIA

1. To pursue proactive and responsive community/public relations. *** *** *** ** o *** *** ** ** *** o ** **

2. To operate plants in a manner which protects the environment and the health and safety of employees and the public. ** *** *** *** o *** ** o ** *** *** ** ***

3. To develop and produce chemicals which can be manufactured, transported, used and disposed of safely. ** *** *** o o ** ** o ** *** ** ** ***

4. To continuously improve their ESH performance. o o o o *** ** *** o o o o o o

5. To promptly notify all affected parties of real and potential hazards arising from their activities and will recommend protective measures. o *** *** ** ** *** *** o ** *** *** ** o

6. To commit to using the best available technology. o o o ** *** o o o o o o o o

7. To evaluate contractors and assure that they have similar ESH commitments and performance. o o o *** *** *** *** o o o *** o o

8. To counsel customers on the safe use of their products, including transportation and disposal. *** *** *** o *** *** *** o *** *** *** ** ***

9. To remediate contamination from previous operations and disposal of hazardous substances. o ** ** o o o o o o ** o o o

10. To commit to resource conservation and/or supporting recycling initiatives. o o o o ** *** o o *** o *** o ***

11. To conduct/support research on the ESH effects of their products, processes and wastes. ** *** *** o ** o *** o o *** *** o ***

12. To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. ** *** *** ** ** o ** o o *** *** *** o

Note: The following national associations either have not developed guiding principles or did not report them in sufficient detail to allow their GPs to be classified here: NZCIC (New Zealand); ANIQ (Mexico); CAIA (South Africa); AICM (Hong Kong); CIQyP (Argentina; VNCI (Netherlands); FCIO (Austria).

Table 2. Index of industry codes of practice under Responsible Care

*** -- indicates the association has detailed a code with comprehensive requirements capable of achieving the code's goals.

** -- indicates that a code exists which does not directly or completely cover this topic, but which can potentially address the issues.

o -- indicates that no code substantially addresses this topic.

Dev. -- indicates that no code exists for this area, but that one is under development.

Inc. -- indicates that incomplete data was provided to make an evaluation, but some form of COP or guidance exists.

Canada CCPA United States CMA Australia PACIA United Kingdom CIA France UIC Japan JCIA Sweden KS Mexico ANIQ Hong Kong AICM Argentina CIQyP Hungary HCIA Korea KPIA India ICMA Portugal APEQ Netherlands VNCI Zimbabwe INCHEM South Africa CAIA Belgium ICB

1. Community awareness/ relations *** *** *** Inc. o o o Dev./inc. o Inc. o Dev. Inc. Dev. ** Dev. Inc. ***

2. Process safety *** *** *** ** o Inc. o Dev./inc. o Inc. o Dev. o Dev. *** Dev. Inc. **

3. Emergency response *** *** *** ** o o Inc. Dev./inc. o Inc. Inc. Dev. Inc. Dev. Inc. Dev. Inc. ***

4. Pollution prevention ** *** *** Inc. o Inc. Inc. Dev./inc. o Inc. o Dev. Inc. Dev. *** Dev. Inc. **

5. Transportation/ distribution *** *** *** ** o Inc. Inc. Dev./inc. Dev. Inc. o Dev. Inc. Dev. ** ** Inc. **

6. Employee health and safety ** *** ** Inc. o o Inc. Dev./inc. o Inc. o Dev. o Dev. ** o Inc. **

7. Product stewardship ** *** *** Inc. o Inc. Inc. Dev./inc. Dev. Inc. Inc. Dev. Inc. Dev. Inc. o Inc. **

Note: The following national associations did not report in sufficient detail to allow their COPs to be classified here: NZCIC (New Zealand), FCIO (Austria).

The following COP summaries are taken from a number of association contributions, though they are primarily from CMA (US)¹ and PACIA (Australia).² The goals stated below are expanded upon in considerable detail by the codes themselves; the details of the codes are not presented in this study due to their length, and the reader is referred to the individual associations (see Responsible Care contacts in Appendix B) for full details of the COP.

Community awareness and relations COP:

Assures that member facilities that manufacture, process, use, distribute or store hazardous materials initiate and maintain a community outreach programme to openly communicate relevant useful information responsive to and addressing the public's questions and concerns about safety, health and the environment. Members will promote an open and ongoing dialogue with employees and the community. Information will be provided about such activities as waste minimization, emission reduction, health effects of chemicals and efforts to ensure the safe transport of chemicals.

Process safety COP:

Designed to prevent fires, explosions and accidental chemical releases. The code builds upon mature process management principles and concepts which have been used for decades in the chemical industry. The code includes a clear accountability for management and oversight of all aspects of process safety, investigation and corrective actions for incidents, regular reviews of processes and procedures, comprehensive safety reviews of new or modified systems or equipment, identification of skills requirements and provision for initial and proficiency training for employees.

Emergency response COP:

To protect employees, communities, property and the environment by provision of effective emergency response plans developed in consultation with the community and emergency services.

Pollution prevention COP:

Seeks to achieve ongoing reductions in the amounts of all pollutants and contaminants released to air, land and water from member facilities. Has the goal of establishing long-term substantial reductions in the amounts of wastes generated and contaminants and pollutants released. States that quantitative reduction goals will be established for those substances of highest health and environmental concern. Calls for a face-to-face and ongoing dialogue with employees and the public on these matters. Some COP call for annual submission of detailed data on releases.

Transportation/distribution COP:

Has the aim of reducing the risk of harm to carriers, distributors, contractors, employees, the general public and the environment posed by the distribution of chemicals. Methods to attain this will include performance of risk assessments, development of new methods and technologies to improve chemical distribution safety and the provision of advice and assistance to persons on the scene of a chemical distribution emergency. This last point has been the subject of much effort in the past, and a number of associations reported comprehensive national systems for responding to emergencies and for aiding the on-scene personnel.

Employee health and safety COP:

Provides a multidisciplinary means to identify and assess hazards, prevent unsafe acts and conditions, maintain and improve employee health and foster communication on health and safety issues. This COP specifies opportunities for employees to participate in developing, implementing and reviewing health and safety programmes. It also calls for means to verify that health and safety programmes and procedures are effective and for maintaining records and analysing data to evaluate health and safety performance, determine trends and identify areas for improvement, as well as verify that health and safety equipment is properly selected, maintained and used. Methods to verify the effectiveness of training and communications are also called for.

Product stewardship COP:

Seeks to make ESH concerns an integral part of the design, manufacture, marketing, distribution, use, recycling and disposal of chemical industry products. Calls for an integration of risk management into all these stages of a product's life, and for extensive interactions with actors outside the company.

Notes:

¹ CMA, Responsible Care - A public commitment, 1994.
² J. Smith, Chemical industry programs - Community, safety and environment, PACIA, 1996.

Updated by BR. Approved by OdVR. Last update: 28 September 2000.