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By Kevin Munn
In reviewing the commitments evident in the various GPs, one sees a wide range of attitudes. The GPs are typically fairly broad statements of principle which either directly state or strongly imply a certain level of corporate ethic and ESH commitment. Table 1 outlines in qualitative terms the level and type of commitment of the national programmes, as perceived by the author. All the programmes called for Responsible Care information exchange within the industry, usually both nationally and internationally. The issues most commonly mentioned in the GPs were community dialogue, emergency preparedness, safe operations and transport, constant improvements in ESH performance, participation in research and in developing legislation, counselling of customers on the safe use, transport and disposal of chemical products, making ESH considerations a priority in both research and development for new products, assuring that contractors adhere to the same high standards, and promoting resource conservation and recycling. No programme made statements on all of these topics. Most did address safe operations and transport, customer counselling and making ESH a priority in operations, R&D and product development. To a lesser extent, public communications and emergency preparedness were also widely covered.
Not all GPs contained definitive or far-reaching goals: some associations would make statements which do not call for direct ESH improvements or would state what should be fairly obvious, such as "The company will assure that the management and personnel at all levels are aware of and apply these principles in all their industrial and commercial activities"3 or "[The company will] comply with all legal requirements which affect its operations and products".4
Most of the GPs are more forthright than the above citations, however, and call for signatory members to initiate actions and take responsibilities which will result in marked improvements in community relations and ESH performance. The tone of the GPs is important in that companies commit themselves to Responsible Care by signing the GPs, and it is usually the CEO who does this. No other explicit pledge to the programme is universally required of all participants by any national association, so (at least to date) the accountability of firms to their commitments rests largely on the obligations which are embedded in the GPs. Though no GPs set out goals which are measurable in quantified terms, statements such as "To act to constantly improve the enterprises' ESH performance",5 "To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public"6 and "Provide the public with the information necessary to enable them to understand the potential environmental effects of the companies' operations and be prepared to respond positively to expressions of public concern",7 declare in no uncertain terms a corporate commitment which goes well beyond the existing legal requirements for public communications or responsibility for operations.
For the majority of associations' members the GPs can serve as a foundation around which firms and other stakeholders can build partnerships and establish goals for improved ESH performance. However, they are inherently difficult to use in evaluating a firm on its performance in achieving these aims. In a few cases, the declarations of the GPs are qualified by such adjectives as "acceptable"8 or "unacceptable"9 levels of risk. The meaning behind such terms is questionable, given the overriding difficulty of defining a viable system of performance indicators for even the unqualified commitments. Such indicators do not yet exist. How does one say that a plant is being operated in a manner which protects the public, employees and the environment? To what extent should this method of measurement be based on the public's opinion, the government's and the company's? What level of communication is sufficient to say that a firm has positively and/or completely responded to the publics' concerns? Should a firm commit to using best available technology regardless of the cost?
To be sure, Responsible Care is an ongoing process of communication and improvement, and the questions raised by the GPs statements themselves merely indicate that further dialogue and development is required beyond the initial commitments and the internal corporate activities. Responsible Care is after all spurred in large part by public perceptions. But it aims to go further than to be simply reactive and to address concerns voiced towards the chemical industry. It espouses a proactive approach: a programme through which the chemical industry will engender a dialogue with government, employees and citizens alike on past activities and problems and on present and future concerns. These are ambitious aims, and one would expect a certain degree of difficulty in changing the habits and attitudes of a sector the size and diversity of the chemical industry.
If the chemical industry is to use Responsible Care as a vehicle of both improvement of ESH performance and public dissemination of these improvements, it must establish a common and understandable reporting mechanism for collecting credible data from companies and for communicating results to the public. The GPs are too general to form the basis of such mechanisms, and are also incomplete as corporate guidance for implementing Responsible Care. Such mechanisms could however be built upon the codes of practice.
Data supplied by national associations on their COPs were not as complete as for their GPs. Additionally, a number of associations have not finished issuing all of their COP. In only four national programmes were the COP found to be complete and detailed guidance to members sufficient to allow a comprehensive verification of code implementation (Canada, United States, Australia and Belgium). That is to say these COP rigorously addressed the stated goals of the GPs and specified both broad management policies and detailed management or operational activities which would be necessary for attaining these goals.
A number of the programmes had developed COP which might be sufficient guidance for members to build a management/operational framework capable of attaining the GPs goals, but which were not described in sufficient detail to provide a basis for objectively measuring performance/completion. Most of the reporting associations either have no or only incomplete COPs, or they did not provide sufficient details to permit their programmes' codes to be judged.
Member companies can, of course, develop internal procedures which are wholly capable of attaining the goals of the GPs without any external guidance. It is the industry as a whole which needs common terms of reference. A company which commits itself to the high standards of Responsible Care has every possibility to put in place unilaterally the necessary external dialogue and internal structures. It is reasonable to then expect that such a firm would utilize certain standard business practices to manage and monitor its activities. These are typically attributes of line management activities, such as "To develop among workers at all levels a sense of their personal responsibility to the environment and to make them aware of the potential pollution risk associated with industrial activity" and, for this activity, the specific requirement, "The material and organizational needs of a personnel training programme have been identified".10 Such statements provide the detail such that a verifier can look for objective evidence -- specific actions and hard data -- that permits a quantitative judgement of compliance. To sufficiently address all the issues in the GPs, these practices must be described in sufficient detail and have considerable scope. The four sets of COP referred to above contain between 150 and 300 specific requirements each. This obviously requires a considerable effort, and can explain why many associations have still not developed a full set of COPs years after they have adopted Responsible Care and a set of GPs.
So how does a company show convincingly that it is doing great things? Some associations have developed self-evaluation aids for their members. Usually modelled after the COP, these can range from broad guidance to detailed descriptions of standard management activities. The verifications which are taking place in the industry are still performed predominantly by the member companies themselves. Statistics were reported by a few national associations on the percentage of their members who have self-verified that they have met all of the requirements of the codes, or the percentage of members who are still in the process of implementing them. The national associations which have full sets of COP and also reported that their members had self-verified substantial progress (by individual code) were CMA (US) and PACIA (Australia).
CCPA (Canada) did not report degrees of completion for the individual COP, but none the less has under way the most advanced verification effort of any national programme; this is through the use of local verification teams.12, 13 These are four-person teams which are wholly independent of the company, composed of ordinary citizens, industry members, environmentalists and academics. Over several days, each team goes on plant tours, conducts extensive interviews, examines company documents and makes calls to neighbours, customers and suppliers. Team members then write a detailed report, and the company shares the results of that report with employees, neighbours and peers.
PACIA ran trial checks in 1994 of its verification scheme, which employs one of three external verifying bodies to visit sites and perform assessments of code compliance. The verifiers review 30-50 per cent of the management practices for the code in question and compare their results with the company's self-assessment. The trial verifications agreed with the company assessment in about 85 per cent of the cases. Eventually all eight COP are to be externally verified.
CMA has initiated its management systems verification (MSV)14 for third-party reviews of the Responsible Care programmes at individual firms. Verification team members are picked from a pool of "trained" individuals; company sites to be visited and persons to be interviewed are chosen by the team; the company then chooses public representatives to accompany the team for the individual visits; the visits are made, the team writes a report and the company (alone) receives a copy of this. The MSV is still under development, and no timetable was given for initiating systematic visits to member sites. Some potential points of contention are the apparent under-participation of the public in choosing the sites to be visited and the lack of either public disclosure of the final report or of company accountability for responding to issues raised by the team. The issue of indemnification of the reviewed firm for any violations discovered by the team is also under discussion.15
Some associations encourage their members to publish annual environmental reports as a part of the promotion of Responsible Care.16 Some companies have turned to independent, third-party verification of their environmental reports as a means of gaining credibility.17
Even the most advanced verification programmes are having trouble getting their message across to the general public. The chairman of the Responsible Care advisory group of the UK Chemical Industries Association, Jim Whiston, reports that neither CMA nor CCPA has seen tangible improvements in public opinion toward the industry since the inception of their programmes.18 CMA-supplied data supports this view; a recent annual survey of the general public in the communities near members' facilities concluding that these neighbours have a positive outlook on the chemical industry only 21 per cent of the time.19 CCPA refers to a ten-year decline in public confidence towards the chemical industry -- a period spanning the entire life of the Canadian Responsible Care programme -- but further indicates that this trend may be bottoming out.20
Is this apparent lack of positive effect from the programme a result of the industry's reporting approach, its presentation of the programme and results to other stakeholders, a certain "momentum" in public opinion, verification/credibility issues, etc.? No one seems to have a complete answer to this, and resolution of this issue is probably one of the largest hurdles facing the programme today.
A recent article on verification methods used for environmental reports and results21 pointed to a number of factors which dilute credibility, including a lack of standards for environmental report contents and report verification methods, verifier qualifications and others. Essentially, the lack of a consistent methodology for assessing corporate environmental reports has led to a predictable variation in reviewers' requirements and techniques for verification. KPMG's Dr. Jan Vernon illustrates the differences and the problems which arise from these, in describing the verification approaches he has observed:
Accounting firms such as ourselves [favour] a rigorous audit methodology and provision of an opinion which reflects our confidence in the data reported, [while verification by] technical/environmental firms appears to be less rigorous and yet gives a strong opinion (e.g. "true and fair" view) which we feel cannot be justified. Reports by environmental firms tend to comment on the good intentions of companies towards the environment rather than focusing on reliability of information. We believe this approach has down-graded the value of verification for business and financial audiences.
Environmental firms, of course, hold contrasting views. Evidently, the belief in a corporate environmental report must also constitute a belief in the organization which provides the verification. The 12 corporate environmental reports (CEPs) reviewed in the article are primarily from western European corporations. The diversity of approaches to verification of CEP is remarkable.
The article also refers to a recent report by the US Investor Responsibility Research Center entitled "Environmental reporting and third party statements", which concluded that "none of the stakeholder groups that participated in this study believed that recent third party statements added much, if any, incremental value to corporate environmental reports published in 1994". Another study by the Public Environmental Reporting Initiative centring on the corporate environmental reports of Amoco and British Petroleum similarly concluded that "third party statements are not a positive factor in stakeholder evaluations of corporate report credibility".
Some of the more advanced Responsible Care programmes are making efforts to involve actors from outside the industry's ranks at the national level. Three associations -- CMA, CCPA and PACIA -- reported that they have formed national advisory panels. These are composed of 12-18 representatives of stakeholder groups which are outside of the chemical industry itself but which have considerable interaction with the industry and which have frequently been critical of it. CIA also reported that it was forming a NAP. The comments of these groups tends to be guardedly optimistic. The CMA NAP notes in its 1995-96 report, "CMA has made the greatest strides in public involvement/responsiveness and external evaluation, and made measurable progress in cultural change. We believe that CMA remains particularly vulnerable on advocacy (specifically on the chlorine debate, audit-privilege legislation and a narrow view to risk assessments), and we see public involvement as the key to effectively addressing this issue."22
CCPA's NAP positively notes the considerable progress made in member company reporting of COP implementation, initiation of management systems verification and the considerable investment made in the training of plant management personnel in community dialogue and risk management, among others. It identifies several areas requiring further development, such as establishing a system of "full cost accounting" in which full social and environmental costs of a product are reflected in its price, extending the concept of product stewardship in the context of sustainability, setting deadlines for the elimination of persistent, toxic, bio-accumulative chemicals, and achieving "phase one" verification of all CCPA members by the end of 1996.23
PACIA's NAP noted "considerable progress (in the past five years) in encouraging the chemical industry to reassess its relationship with its community", yet argued "strongly that if industry desires to develop effective community-company relationships then it must move toward an acceptance of the principle of `company obligation to tell', rather than simply `community right to know'" and notes that "unfortunately, some executives (of PACIA member companies) are still of the view that because a company provides economic outcomes and employment to its community, it should be forgiven for any environmental or community health issues to which it contributes". The panel further details issues for future consideration:
-- companies continuing to produce and sell chemicals when some research results or community outcomes have pointed to potential detrimental effects;
-- companies continuing to produce and sell to developing countries, chemicals where use is banned or restricted elsewhere;
-- communities who observe unusual effects of chemicals on their physical environments or their human inhabitants.24
Linked to the verification dialogue is the topic of how one measures performance. In fact, for this study, the whole issue of performance indicators under Responsible Care is a contentious one. Few performance indicators that were reported by any of the associations could be said to arise strictly from their Responsible Care programmes. Appendix A mentions the performance indicators which are reported by the individual associations in their programme documents.
Overall, reporting of performance indicators is not widespread, with perhaps half of the associations indicating that they published performance indicators under their programmes. The indicators most commonly cited are workplace accidents (generally lost time, total days off and/or fatalities), transportation incidents and wastes generated (frequently subdivided into various categories). In almost all countries where these figures are reported, the cited statistics were already required reporting under existing legislation. This data is completely relevant to the Responsible Care programme, and constitutes readily available quantified data which it would be silly to ignore. However, external stakeholders could very easily be sceptical about the extent of the voluntary efforts being made under Responsible Care if they are presented only with data which is legally required under existing legislation.
Some associations are reporting data which is derived directly from their programmes. CMA reports attitudes of target groups towards the chemical industry; an annual survey of general public, plant neighbours, emergency response personnel and industry employee opinions of the chemical industry has taken place since 1994.25 CIA reports on complaints received by plants from the surrounding communities.26 PACIA collects surveys from its members' community advisory panels and reports the degree of satisfaction of these multi-stakeholder groups with the local companies.27 PACIA has also developed a plant incident measure of performance, and has surveyed community groups to assess the information they would like to see reported in the future. Both PACIA and CMA report the degree to which their members have completed implementing the individual COPs. APEQ (Portugal) reports safety and health costs (though these are not well defined in the literature), workplace noise levels, direct health costs (treatments, insurance, etc.), total waste (both for recycling and for disposal) and unit consumption of water and energy.28 VNCI (Netherlands) reports29 extensive environmental data, but this is not derived directly from its Responsible Care programme and is reported in the chapter on national, bilateral initiatives.
For the data which is collected, there have generally been favourable trends in workplace and transportation accidents, fugitive emissions and wastes generated. The polls of CMA have shown some slight improvements in opinion, more so among employees and emergency response workers, whose opinions of the industry tend to be favourable about 50 per cent of the time, than among the general public and plant neighbours, who continue to give the industry a positive rating in only about 20 per cent of the cases.30 PACIA members get quite high ratings from the local community panels. CIA reports that the number of plants with a local community relations panel has continued to grow, though 1995 also saw a noticeable rise in the number of complaints received by facilities. CMA and CCPA also report steady increases in recent years in the number of existing community advisory panels.
3 UIC, Engagement de Progrès -- Bilan Exercice 1995
4 CCPA, Responsible Care -- A total commitment
5 ICB, Responsible Care: un engagement de l'industrie chimique
6 CMA, Responsible Care progress report, 1995-1996
7 CEFIC, Responsible Care -- A chemical industry commitment to improve performance in health, safety and the environment
8 CIA, Responsible Care -- Improving health, safety and environmental performance in the chemical industry
9 CMA, Responsible Care -- A public commitment
10 ICB, Responsible Care -- Guide de mise in application et d'auto-évaluation
11 E. Kirschner, Chemical and Engineering News
12 CCPA, Responsible Care 1995 -- A total commitment
13 CCPA, Responsible Care -- Compliance verification
14 CMA, CMA Responsible Care management systems verification information kit
15 Telephone interview with D. Roczniak, 26 Nov. 1996.
16 CEFIC, Responsible Care -- A chemical industry commitment to improve performance in health, safety and the environment
17 European Chemical News
18 op. cit., 1-7 July 1996, p. 5.
19 CMA, Environmental health and safety performance report, 1995-1996
20 CCPA, Does Responsible Care Pay? ... a primer on unexpected benefits of the initiative
21 J. Elkington and S. Fennel, Tomorrow
22 CMA, Responsible Care progress report, 1995-1996
23 CCPA, Responsible Care 1995 -- A total commitment
24 PACIA, Responsible Care News
25 CMA, Environmental health and safety performance report, 1995-1996
26 CIA, The UK indicators of performance, 1990-1995
27 PACIA, Local community advisory panels continue to grow in Australia
28 APEQ, communiqué from L. Penedo to K. Munn, 16 Dec. 1996.
29 Dutch Ministry of Housing, Physical Planning and Environment (VROM), "Declaration of Intent on the Implementation of Environmental Policy for the Chemical Industry", The Hague, 2 Apr. 1993.
30 CMA, Environmental health and safety performance report, 1995-1996
