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Voluntary initiatives affecting training and education on safety, health and environment in the chemical industries 

Report for discussion at the Tripartite Meeting on Voluntary Initiatives Affecting Training and Education on Safety, Health and Environment in the Chemical Industries

Geneva, 22-26 February 1999

International Labour Office   Geneva

Copyright ® 1998 International Labour Organization (ILO)

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Contents

List of abbreviations

Introduction

1. Voluntary initiatives on health, safety and environment

1.1. What are voluntary initiatives?
1.2. Why voluntary initiatives in the chemical industries?
1.3. Types of voluntary initiatives

1.3.1. Industry initiatives
1.3.2. Environmental agreements
1.3.3. Environmental management schemes and standards

1.3.3.1. European Union Eco-Management and Audit Scheme
1.3.3.2. International Organization for Standardization
1.3.3.3. Industry acceptance of EMAS and ISO

1.4. The relationships between the VI schemes and standards

2. Chemical industry initiatives

2.1. Responsible Care

2.1.1. Structure of RC
2.1.2. Status of RC development worldwide
2.1.3. Employee and public recognition of RC
2.1.4. Worker involvement in RC
2.1.5. RC performance indicators

2.2. Responsible Distribution/Care

2.2.1. Structure of Responsible Distribution
2.2.2. Performance indicators

2.3. Coatings Care

2.3.1. Relation to Responsible Care
2.3.2. Structure of Coatings Care

2.4 The pesticide industry's Global Safe Use Initiative

2.4.1. Summary of results
2.4.2. Future developments
2.4.3. A trade union perspective

3. Voluntary initiatives and HSE training and education

3.1. The impact of VIs on HSE training and education
3.2. Company and plant-level training and education, including SMEs

3.2.1. Management training
3.2.2. Blue-collar worker training
3.2.3. Trade union/worker representatives
3.2.4. Contractor training
3.2.5. The role of small and medium-sized enterprises (SMEs)

3.3. Trade association training and education activities

3.3.1. Industry awareness raising
3.3.2. The role of trade associations in developing and rapidly industrializing countries

3.4. Chemical distribution/supply training and education

3.4.1. Transport
3.4.2. Product stewardship

3.5. Outreach training and education

3.5.1. Community activities
3.5.2. Education programmes for schools, colleges and universities

3.6. Evaluating the impact of VIs on HSE training, education and performance

4. Summary and points for discussion

Suggested points for discussion

List of figure and boxes:

Figure 2.1. Number of courses in environment, health and safety and number of participants as a proportion of total personnel

Box 1.1. Conditions appropriate for environmental agreements (EAs)

Box 1.2. Corporate HSE reports

Box 1.3. Safety, Environment and Quality (SHEQ) Management Systems and Management Systems Standards

Box 1.4. The main differences between EMAS and ISO 14001

Box 1.5. The relationship of Responsible Care with EMAS and ISO 14001

Box 2.1. RC membership/endorsement criteria

Box 2.2. How do companies implement Responsible Care? One manager's view

Box 2.3. The Global Forum on Chlorine Chemistry

Box 2.4. Voluntary industry initiatives versus industry agreements: A view from the ICEM

List of abbreviations

ACIC	Australian Chemical Industry Council
AICM	Association of International Chemical Manufacturers
ABIQUIM	Brazilian Chemical Industry Association
ANIQ	Mexican Chemical Industry Association
ASIQUIM	Chilean Chemical Industry Association: Asociación Gremial de Industriales Químicos, Chile
BCDTA	British Chemical Distributors' and Traders' Association
BCF	British Coatings Federation
BS 7750	British Standard 7750
CAER	community awareness and emergency response
CAIA	Chemical and Allied Industries Association, South Africa
CAP	Community Advisory Panel
CC	Coatings Care
CCPA	Canadian Chemical Producers' Association
CEFIC	European Chemical Industry Council
CEP	company environmental reports
CEPE	European Council of the Paint, Printing Inks and Artists' Colours Industry
CIA	Chemical Industries Association, United Kingdom
CICM	Chemical Industries Council of Malaysia
CICT	Chemical Industries Club of Thailand
CIQyP	Argentinian Chemical Industry Association
CMA	Chemical Manufacturers' Association (United States)
COP	code of practice
CSD	Commission on Sustainable Development (United Nations)
CSG RENGO	Federation of Chemical, Service and General Trade Unions
DIEP	Declaration of Intent of the Implementation of Environmental Policy for the Chemical Industry, the Netherlands
EA	environmental agreement
EC	European Commission
EEA	European Environment Agency
EMAS	(European Union) Environmental Management and Eco-Audit Scheme
EMS	environmental management system
EPA	Environmental Protection Agency, United States
EU	European Union
FAO	(UN) Food and Agriculture Organisation
FCIO	Austrian Chemical Industry Association
FECC	European Association of Chemical Distributors
FEIQUE	Spanish Chemical Industry Association
GCPF	Global Crop Protection Federation (formerly GIFAP)
HACI	Hellenic Association of Chemical Industries, Greece
HCIA	Hungarian Chemical Industry Association
HSE	health, safety and environment
HSRC	Human Sciences Research Council (South Africa)
ICCA	International Council of Chemical Associations
ICCTA	International Council of Chemical Trade Associations
ICEM	International Federation of Chemical, Energy, Mine and General Workers' Unions
ICFTU	International Confederation of Free Trade Unions
ICM	integrated crop management
ICMA	Indian Chemical Manufacturers' Association
ICRI	Industrial Chemistry Research Institute, Poland
IEA	International Energy Agency
IEC	International Electrotechnical Commission
IFCS	Intergovernmental Forum on Chemical Safety
ILO	(UN) International Labour Organization
INCHEM	Industrial Chemical Association of Zimbabwe
IPM	integrated pest management
IPPIC	International Paint and Printing Inks Council
ISO	International Organization for Standardization
IUF	International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations
JCIA	Japan Chemical Industry Association
JEC	joint union-management environment
JHSC	joint union-management health and safety committees
JRCC	Japan Responsible Care Council
KPIA	Korean Petrochemical Industry Association
KS	Kemikontoret Service AB, Sweden
KT	Chemical Industry Federation of Finland
LCA	life cycle assessment
MSD	material safety data sheet
MSV	management systems verification
NACD	National Association of Chemical Distributors, United States
NAP	National Advisory Panel
NPCA	National Paints and Coating Association, United States
NGO	non-governmental organization
NZCIC	New Zealand Chemical Industry Council
OSH	occupational safety and health
OSH MS	occupational safety and health management system
OSHA	Occupational Safety and Health Administration, United States
PACIA	Plastics and Chemicals Industries Association (Australia)
PIL	Federation of Norwegian Process Industries
PIPC	Polish Chamber of the Chemical Industry
PIRG	public interest research group
PPE	personal protective equipment
PS	product stewardship
RC	Responsible Care
RCLG	Responsible Care Leadership Group (of the ICCA)
RD	Responsible Distribution
SCC	Safety Checklist Contractors, the Netherlands
SCHP	Association of the Chemical Industry of the Czech Republic
SD	sustainable development
SGCI/SSIC	Swiss Chemical Industry Association
SHEQ	safety, health, environment and quality management systems and management system standards
SME	small to medium-sized enterprise
TRCA	Taiwan Responsible Care Association
TRI	Toxics Release Inventory (United States)
UIC	Union des Industries Chimiques, France
UNCED	United Nations Conference on Environment and Development: The Earth Summit
UNEP	United Nations Environment Programme
UNFCC	United Nations Framework Convention on Climate Change
UNGASS	UN General Assembly Special Session: Rio +5
VCI	German Chemical Industry Association
VEEP	Voluntary Energy Efficiency Programme (Europe)
VI	voluntary initiative
VNCI	The Netherlands Chemical Industry Association
VOC	volatile organic compound
VPP	voluntary protection programme
VROM	Ministry of Housing, Physical Planning and Environment, the Netherlands
WCC	World Chlorine Council
WG	working group
ZCHFP	Association of Chemical and Pharmaceutical Industry of the Slovak Republic
ZEW	(German) Centre for European Economic Research

Introduction

The last ILO tripartite sectoral meeting devoted to the chemical industries, held in 1995, adopted a resolution in which it called on the Director-General to convene a future meeting on the chemical industries "to examine programmes established under voluntary initiatives such as the Responsible Care programmes, as those programmes affect training and education on safety, health and environment".⁽¹⁾ The Governing Body, at its 267th Session (November 1996), endorsed that recommendation by including in the programme of sectoral meetings for 1998-99 a tripartite meeting on "voluntary initiatives affecting training and education on safety, health and environment" in the chemical industries.⁽²⁾

The rationale for the meeting, as stated in the document before the Governing Body, was as follows:

This proposal alludes especially to the programme called Responsible Care [Fr.:Engagement de Progrès; Sp.: Conducta responsable], which is a major industry-wide voluntary effort by employers to "clean up their act" and be seen to do so. It was judged important to stress particularly the training and educational aspects of the programme, since lack of understanding of health and safety education issues -- by the workforce, communities where chemical plants are located, and the general public -- is seen as one of the biggest threats to the industry's profitability and job outlook.⁽³⁾

The Governing Body fixed the purpose of the meeting in the following terms:

To exchange views on voluntary initiatives affecting training and education on safety, health and environment in the chemical industries; to adopt conclusions that include guidance and proposals for further action; and to adopt a report on the discussion. The meeting may also adopt resolutions.⁽⁴⁾

It was also decided that the Employer and Worker representatives to the meeting would be appointed on the basis of nominations made by the respective groups of the Governing Body.

Governments of the following 23 countries have been invited to participate in the meeting: Argentina, Armenia, Brazil, China, Czech Republic, Denmark, Egypt, Germany, Hungary, India, Italy, Japan, Mexico, Morocco, Nepal, Netherlands, Norway, Pakistan, Russian Federation, South Africa, Turkey, United Kingdom and United States. The following governments were placed on a reserve list from which replacements were to be selected in the event that a government in the first list declined the invitation or failed to reply: Algeria, Barbados, Chile, Finland, Ghana, Islamic Republic of Iran, Nicaragua, Romania, Switzerland, Thailand, Tunisia and United Arab Emirates.

This report has been prepared by the International Labour Office as a basis for discussions at the meeting. It was prepared by Peter Hurst, ILO Occupational Safety and Health Specialist, under the responsibility of Jon McLin, Senior Industrial Specialist, Sectoral Activities Department, ILO. It is published under the authority of the International Labour Office. In response to a request of the last sectoral meeting, an earlier, less formal document on voluntary initiatives was published in the form of a Sectoral Activities Programme Working Paper,⁽⁵⁾ and was widely circulated; account has been taken in the present report of the comments received in that exercise. Other information has been supplied by, or through the good offices of, employers' and workers' organizations active in this sector. In particular, important contributions have been made by the European Chemical Industry Council (CEFIC), both in its own capacity and in its role as secretariat for the International Council of Chemical Associations (ICCA); by the International Chemical Employers' Labour Relations Committee; and, for the workers, by the International Federation of Chemical, Energy, Mine and General Workers' Unions (ICEM).

Documenting the relation between voluntary initiatives and training and education related to health, safety and environment is not a straightforward matter, for several reasons. One is that experience of voluntary initiatives is relatively recent and not all countries or regions have participated in them equally. Another is that of the training activities carried out by the chemical industries on health, safety and environment, it is difficult to identify which ones are attributable specifically to the voluntary initiatives, or how pre-existing training activities have been modified as companies and trade associations have committed themselves to the voluntary initiatives. Another difficulty concerns data collection and reporting. The ultimate aim of health, safety and environment (HSE) training and education in the context of voluntary initiatives is to improve HSE performance as measured, for example, by cutting lost-time accidents, reducing polluting emissions, etc. Industry is collecting data on, and developing indicators to measure, such HSE performance improvements. It is not necessarily collecting data or reporting on the means -- in this case, training and education -- by which improvements are achieved. Hence on certain aspects there was a shortage of relevant data. Nevertheless, the report is presented in the hope that it will provide the meeting with a satisfactory basis for its deliberations.

1.  ILO: Chemical Industries Committee, 11th Session, Note on the proceedings, Geneva, 1995, resolution No. 69, p. 53.

2.  GB.267/11, Nov. 1996.

3.  GB.267/STM/1.

4.  Programme of sectoral meetings, 1998-99, SM/1997/D.1.

5.  Kevin Munn: Responsible Care and related voluntary initiatives to improve enterprise performance on health, safety and environment in the chemical industry, Sectoral Activities Programme Working Paper No. 109 (available in English only), Geneva, 1997.

1. Voluntary initiatives on health, safety and environment

Voluntary initiatives (VIs) -- that is, codes of conduct or other enterprise initiatives not required by law, which address the performance of enterprises in respect of occupational health, safety, the environment (HSE) and other issues -- are becoming more prevalent. They are increasingly seen as a new policy instrument and management tool to help tackle HSE problems. They are promoted not only by the industries themselves but also by governments, often cash-strapped, who see a mix of government and voluntary (self-) regulation as a way of achieving higher standards in a more efficient and cost-effective manner than through "command-and-control" type regulation alone. Other groups such as trade unions are also taking an increasing interest in VIs and their roles within them. The chemical industry has been a leader in promoting VIs for reasons discussed in section 1.2 below.

1.1. What are voluntary initiatives?

The term voluntary initiatives can be understood in various ways. A recent UNEP Report on Voluntary Industry Codes of Conduct for the Environment notes that:

A wide range of terms is used to describe voluntary initiatives for environmental protection such as the environmental charter, environmental principles, environmental guidelines, environmental codes of practice, environmental codes of ethics and environmental commitment. Each may have different cultural, language, contextual, political and legal implications and even their definitions can have different meanings in different contexts. Even within a country, the same term can have different meanings.⁽¹⁾

A later supplement to the UNEP Report states that the term voluntary initiatives encompasses the following categories:

• voluntary agreements between industry and government;
• voluntary programmes of industry;
• voluntary standards such as those of the International Organization for Standardization (ISO);
• voluntary codes of conduct, guidelines, principles, statements, policies, etc.⁽²⁾
• A report⁽³⁾ comparing VIs in Austria and the United Kingdom lists the following types of voluntary programmes:
• voluntary agreements (e.g. on the reduction of emissions in the Netherlands);
• voluntary initiatives (e.g. Responsible Care);
• voluntary commitments, e.g. the European Union's Eco-Management & Audit Scheme EMAS.

(These examples are explained below.)

There is some dispute as to whether the "voluntary agreements" are genuinely voluntary, since they may involve legal commitments between industry and government. This is discussed in section 1.3.

In practice, voluntary initiatives range from arrangements in which the parties (usually enterprises or their associations) set their own targets and often do their own monitoring and reporting, to initiatives where an understanding is reached between a non-commercial body (e.g. a government authority, a citizen's organization, or a non-governmental organization) and a commercial party (an industry association or a particular company). The declared intent of the two types of initiative is usually the same: to stimulate members to voluntarily improve their environmental or general HSE performance. The premise is that by fostering long-term, cultural changes in business management, voluntary approaches can reach beyond some governmental regulations in improving industry's environmental [or HSE] performance.⁽⁴⁾ One central feature that they all have in common is that they attempt to tap market forces to improve performance and standards.

Based on the premise that the overall intent and results of industry's voluntary initiatives are more important than their precise definition, this ILO Report takes a broad view of the term "voluntary initiatives". It therefore covers company and industry-wide initiatives, government-industry environmental agreements, and environmental management systems.

Whilst recognizing that it is now widely accepted in most countries that a combination of regulatory and voluntary measures is increasingly the basis for HSE management systems, this Report, like the UNEP Report, is based on the premise that "voluntary codes cannot be effective without a sound government regulatory and policy framework and public involvement."⁽⁵⁾ This position is consistent with various international labour standards and conclusions of tripartite meetings.

Voluntary programmes are only one element of a comprehensive HSE protection strategy that includes a range of policies and programmes. They have important strengths and present particular challenges that should be recognized to ensure that they are used most successfully.⁽⁶⁾

• The strengths which make them powerful policy instruments are that they:
• use a market-based approach to encourage behavioural change that is not dependent on regulation;
• provide valuable benefits for participants, including access to low-cost information, reduced operating costs, and public recognition for their HSE accomplishments;
• tend to create partnerships between potential adversaries (government and industry, corporate competitors within an industry, industry and trade unions), which leads to improved dialogue and cooperation that can benefit all parties;
• can have far-reaching effects, influencing behaviour by changing the attitude of the public towards the chemical industry thus leading to improvements on many fronts.

The limitations of voluntary programmes, which are linked to their reliance on market forces, are that:

• they can be successful only when participants can be persuaded to change their actions voluntarily. Therefore, a careful analysis of opportunities and participant motivations is appropriate before choosing a voluntary approach;
• as the prospect of sanctions for non-compliance tends to be absent or weak, voluntary programmes may not be compelling enough to entice participants to change their behaviour;
• voluntary programmes often lack transparency and may fail to protect third-party rights; credible monitoring, evaluation and reporting components are needed to establish credibility with important stakeholders;
• voluntary programmes can violate competition rules in various ways, according to the European Commission. For example, non-signatory companies can be excluded from a market; or consumer prices can be inflated. The Commission points out, however, that this is not a significant obstacle to the use of voluntary programmes.⁽⁷⁾

1.2. Why voluntary initiatives in the chemical industries?

That the chemical industry has been a leading sector in introducing VIs can be attributed to its need to improve the public perception of its performance on occupational and public health and safety and on pollution prevention and control. Generally, the chemical industry suffers from a poor public image and low levels of public confidence owing to increasing chemical pollution in many parts of the world, and a series of well-publicized major chemical disasters such as Seveso, Bhopal and Basel. As a consequence, the industry feared increased government regulation, growing public opprobrium, difficulty in recruiting top-quality staff, and the threat of lawsuits in some countries.

As one writer for a chemical industry magazine put it, "That the chemical industry has a poor public reputation is a belief strongly held within the industry itself."⁽⁸⁾ The European Chemical Industry Council (CEFIC) has carried out a series of polls on public attitudes to the industry, aimed especially at assessing the impact of Responsible Care (RC) on public attitudes. The 1994 poll, based on a sample of 7,300 people in Belgium, France, Italy, the Netherlands, Spain and the United Kingdom⁽⁹⁾ showed that despite some improvements, the chemical industry continued to have a poor standing in public opinion. Only 39 per cent of those questioned gave it a positive rating, compared to 56 per cent for the automotive industry, 74 per cent for the food sector, and 80 per cent for the telecommunications industry. Only 46 per cent agreed with the proposition that it "deserves to be trusted". Only 24 per cent concurred with the proposition that the industry "informs the public fairly and openly"; 88 per cent of the public wanted the chemical industry to be controlled by "far stricter regulations", a figure which varied little between countries, ranging from 81 per cent in Germany to 92 per cent in Spain. However, 50 per cent accepted that chemical companies were "informing the public more factually and openly" than two years earlier, and two-thirds agreed with the proposition that the industry was "making considerably greater efforts to control pollution than it did two years ago".

The 1996 CEFIC poll of 7,000 people showed that opinions in Belgium, France, Italy, the Netherlands, Spain and the United Kingdom had changed little since the 1994 poll. Key findings were as follows:

• Reputation: the industry had retained its position as second only to the nuclear industry as the least reputable of eight sectors.
• Trustworthiness: the proportion of the public who felt that the industry deserved to be trusted had fallen in nearly all countries. The results were most bleak in the UK, where a little over 20 per cent of the public trusted the industry.
• Voluntary initiatives: less than one-third of the United Kingdom public believed voluntary programmes of the chemical industry itself to be more effective than further laws and regulations.
• Responsibility: fewer people than in 1994 believed that the industry was making greater efforts to control pollution, and that it was fair and open with its information. This last finding comes despite the growing number of chemical companies publishing environmental reports.⁽¹⁰⁾

In the United Kingdom, opinion polls conducted by the Chemical Industry Association (CIA) have shown that the 1980s were a decade of decline in public confidence in the chemical industry from 40 per cent public favourability in 1980 to 20 per cent in 1990. A 1989 poll showed that in terms of public favourability, the chemical industry was next to bottom; only nuclear power fared worse.⁽¹¹⁾ A 1998 CIA survey of 4,028 people found that 23 per cent viewed the industry unfavourably and 23 per cent favourably; about 50 per cent were undecided.⁽¹²⁾

In a 1992 opinion poll carried out for the United States Chemical Manufacturers' Association (CMA), the chemical industry scored a 25 per cent favourability rating, ranked below the nuclear industry which scored 35 per cent. The 1993 figure was again 25 per cent, while 35 per cent of respondents had an unfavourable attitude and 40 per cent were undecided. The improvement by 1993 was attributed by the CMA to the industry's information programmes and to the Responsible Care initiative.⁽¹³⁾ In 1991, CMA had begun an outreach campaign to communicate with the public about the industry's RC activities and improve public perception of the chemical industry. Another 1993 poll similarly concluded that there had been "a fairly strong turnaround in public opinion"; the 10 per cent of respondents that the Roper poll considered as influential Americans showed an increasingly favourable stance to the chemical industry.⁽¹⁴⁾ This turnaround has continued. According to CMA's 1997 RC report, the outreach campaign stopped a 25-year decline in the general public's opinion of the chemical industry.⁽¹⁵⁾

Since the 1980s, the chemical industry in most parts of the world has been developing initiatives to voluntarily improve its performance on health, safety and environment (HSE) and, to counter its poor image, to be seen doing so. These industry-initiated programmes, which are described in Chapter 2, aim at continuous improvement of HSE performance on a national, regional and global basis. Furthermore, the industry aims to communicate, and in some instances demonstrate by third-party verification, that the improvements are genuine, not just a "public relations gimmick".

These initiatives are generally viewed by the industry as part of its commitment to the goal of sustainable development (SD), a concept adopted by the United Nations Conference on Environment and Development (UNCED) in 1992 and promoted worldwide through the Agenda 21 programme.⁽¹⁶⁾ In its position paper on SD, the International Council of Chemical Associations (ICCA) says:

Commitment by the world chemical industry to the concept of sustainable development requires words to be transposed into company-specific action programmes in order to provide a framework for all those working in the sector. Its "Responsible Care" initiative, self-monitoring systems and other voluntary programmes such as sustainable technology (SUSTECH), education-industry partnerships, energy efficiency programmes are also part of this framework. Thereby, companies are also confronted with new challenges and must act responsibly. They must take account of their actions upon society and future generations.⁽¹⁷⁾

In a given country, however, not all companies may have joined a relevant VI, and this is especially the case for small and medium-sized enterprises (SMEs). Hence the important role played by national trade associations in encouraging the raising of standards in all companies, bringing along industry laggards, and trying to ensure that "black sheep" do not continue to give the industry a bad name even though the majority of companies are actively and voluntarily seeking to improve their performance.

Pressure for VIs has also come from other sources. Government has played a dual role. First, the threat of increased government legislation, backed by public opinion hostile to the chemical industry, has been a driving force. The industry has realized that to counter this threat, it needs to prove that voluntary programmes can work and be cost-effective. The German Chemical Industry Association (VCI), for example, says that to reduce government intervention in environmental management it must first raise awareness about Responsible Care. It hopes to achieve this through dialogue with the European Commission and the German Land governments. As VCI's RC coordinator says, "Our aim is to bring politics and stakeholders into [our] boat rather than the other way round."⁽¹⁸⁾ Secondly, and at the same time, in respect of HSE regulation governments have been moving away from command-and-control models to those that are more goal-oriented, whereby both parties (government and industry) agree on common goals and timetables while the method of realization is left to the industrial sectors and companies themselves to work out. Section 1.3 deals with this issue and gives examples. Indeed, in some circumstances, industry sees VIs as a substitute for regulation, as evidenced by an ICCA statement in 1996 to the Intergovernmental Forum on Chemical Safety (IFCS) to the effect that:

The ICCA further seeks national governments' understanding of the work we are doing and of the major importance of voluntary industry initiatives to complement and, where appropriate, replace regulation and thereby protect human health and the environment.⁽¹⁹⁾

The other main source of pressure to adopt VIs is the trend toward independently certified management systems and standards, which companies agree to adhere to and implement on a voluntary basis to improve their HSE efficiency and image. These are having an increasing impact on company and industry performance worldwide. International Organization for Standardization (ISO) systems and standards evolved from quality management systems, whilst the European Union Eco-Management and Audit Scheme (EMAS) also involves certified and reportable, third-party verification.

In summary, the three considerations of government regulation, public opprobrium, and (in some countries) lawsuits have led to VIs such as Responsible Care. There has been a ratcheting-up effect in the way in which industry has taken on these initiatives. Each initiative has created expectations and provided a platform for stakeholders and industry critics to point out the shortcomings of the VI. This has led in turn to efforts to make existing VIs more complete and/or transparent and to complement them with others to address related issues. There is little evidence that this process has run its course.

1.3. Types of voluntary initiatives

This report divides VIs in the chemical industries into the following categories, giving a general description of each, with a focus on training and education where such information is available:

• Chemical industry initiatives: industry-wide programmes executed at the company, corporate and trade association levels.
• Environmental agreements between government and industry.
• Environmental management systems and standards: European Union Eco-Management and Audit Scheme (EMAS) and the environmental management systems and standards of the International Organization for Standardization (ISO).

1.3.1. Industry initiatives

The main industry initiatives dealt with in this report are Responsible Care, Responsible Distribution/Care, Coatings Care, and the Pesticide Global Safe Use Initiative. Responsible Care and Coatings Care cover chemical and coatings manufacturing. Responsible Care is the longest established of all the initiatives, having started in Canada in 1984, and now encompasses national programmes in some 40 countries. Coatings Care is more recent and only became fully operational in 1997-98; there is little to report so far concerning its impact on HSE training and education. Chemical distributors have developed their own programme entitled either Responsible Distribution or Responsible Care, depending usually on whether a partnership agreement has been signed with the chemical manufacturing Responsible Care organization in a given country. The geographical coverage of this programme is at present more restricted than that of Responsible Care for manufacturing, being limited to distributors in North America, Europe and Japan. The pesticide industry has developed a Global Safe Use Initiative which encompasses hundreds of separate projects in both developed and developing countries. Three of these projects, entitled Pesticide Safe Use Pilot Projects, provide voluntary training for users and handlers of agricultural pesticides in developing countries; these are examined in Chapter 2.

Of all voluntary initiatives covered in this report, these industry-wide efforts, especially Responsible Care, are the most advanced. They have a wide body of industry support and more relevant experience to report on in respect of HSE training and education. These initiatives are dealt with in more detail in Chapter 2. The remainder of this chapter is devoted to the other initiatives, in particular environmental agreements, and environmental management systems and standards which are newer and still being implemented in many companies and countries; there is correspondingly less empirical evidence concerning their impact on HSE training and education. The corporate HSE report is another category of industry-initiated VIs that is briefly touched on in box 1.2.

1.3.2. Environmental agreements

The term "environmental agreements" (EAs) used in this report covers those commitments undertaken by firms and sector associations which are the result of negotiations with public authorities and/or explicitly recognized by the authorities. This definition is used by the European Environment Agency (EEA) of the European Union, a region in which such agreements are common. By 1996, for example, more than 300 EAs had been concluded at the national level in the EU, that is, are currently recognized by national authorities of EU countries.⁽²⁰⁾ All EU countries are reported to have EAs. The Netherlands leads the way with over 100 in place. Many of the EAs implemented in EU countries to date are found in those sectors where most pollution occurs -- such as metals and metal finishing, chemicals, energy, transport -- with more than 20 per cent of the total number of EAs operational in the chemical sector. Furthermore, this figure of 300 EAs may be deceptively low because it excludes EAs that have been concluded at the subnational level.

The same European Environment Agency (EEA) report on EAs observes that:

Since the late 1980s, there has been increased use of environmental agreements (EAs) as policy tools in EU Member States, especially in industry and waste management. This approach to environmental management mirrors current trends of consensus-building and participatory processes in public policy and complements the traditional command-and-control approach. EAs reflect both the development of shared responsibilities and the integration of environmental considerations into company management structures.⁽²¹⁾
 

The EEA report states, however, that there is no standard definition of "environmental agreements" which are also known as "voluntary agreements", "negotiated agreements" or "covenants". The term, in fact, covers different types of agreements ranging from voluntary "codes of conduct" to legally binding agreements.⁽²²⁾ Similarly, the European Union Communication on EAs states that they may be legally binding with obligations for both parties, or they may be non-binding "gentleman's agreements" in the form of a unilateral commitment recognized by the public authority.⁽²³⁾ The European Commission argues that the term voluntary agreement, despite its wide usage, is confusing and suggests a pull-back from regulation. It considers that the terms covenant, negotiated agreement or environmental agreement are more accurate and preferable.⁽²⁴⁾ It further notes that EAs are valued for fostering partnership between industry and public authorities and drawing on industry expertise for achieving enhanced environmental protection. The Communication goes on to say that EAs "can bring about effective measures in advance of legislation and thus reduce the volume of regulatory and administrative actions. However, environmental agreements are not a panacea and need to be applied in a mix of policy instruments, i.e. as a supplement to legislation and environmental taxes". They also "have the advantage of encouraging a proactive approach from industry, they are likely to lead to cost-effective measures, because they allow industry to adjust environmental investment to their medium-term capital investments, and they are usually in place than regulations are, which is an important advantage in areas with technological developments".⁽²⁵⁾ The EEA Report also notes that EAs appear to be most useful when they complement other policy measures, such as regulation and fiscal instruments. In its view they can be especially valuable in terms of their ability to raise awareness, create consensus and provide a forum for information sharing among different parties. EAs also seem to be useful in improving environmental management in industry and business.

Some concerns have been expressed, however, about the rise of EAs as a new policy instrument, particularly by third parties such as non-governmental organizations (NGOs) and trade unions not involved in the negotiation of the agreements. These concerns include lack of mechanisms and sanctions to ensure the objectives are met, lack of transparency, and lack of third-party verification.

The European Commission argues that wherever possible, environmental agreements should be legally binding. Its Communication on EAs notes that "not all of the past 'voluntary' agreements were transparent and credible. The Commission therefore suggests that interested parties should be consulted before an agreement is concluded and that agreements should, wherever possible, be binding to the parties".⁽²⁶⁾ Where not legally binding, transparency and publicity should in the Commission's view compensate for the weaker sanctions provided. Furthermore, agreements should go beyond best effort clauses and include quantified targets. Clear monitoring measures should be defined. Third-party verification is also suggested as well as the publication of the agreement and of the results achieved.

Concerning the effectiveness of EAs, the EEA Report concludes that:

Compared to other policy instruments, e.g. taxes, few evaluations of EAs, whether ex-ante or ex-post, have been made and there is little literature available on their use ... [and] ... In most cases it was not possible to make a quantitative assessment of the environmental effectiveness of the agreements due to the lack of reliable monitoring data and consistent reporting, which prevented comparisons being made between the current situation and what would most likely have happened if no agreement had been concluded (the 'business-as-usual' situation). Some wider benefits were found, however, including environmental improvements on the situation prior to the agreement and the encouragement of environmental management in business.⁽²⁷⁾

However, a report commissioned by the German Government was highly critical of certain VIs. It argued that negotiated environmental agreements between industry and government, because they are unenforceable, could weaken environmental protection. It also claimed that the bargaining process results in lower environmental standards. The study was commissioned by the German Ministry of Economic Affairs from ZEW, a German economic research institute. The institute examined three current examples of German EAs: a take-back scheme for the automotive industry, CO₂ reduction by a group of industries and the "green dot" DSD packaging recovery scheme. The report concluded: "Agreements are not the remedy of first choice -- they are non-binding and difficult to enforce. In the bargaining situation, the targets you are aiming at have to be reduced and you do not achieve what could be done with environmental law."⁽²⁸⁾

Examples of environmental agreements (EAs)

In the Netherlands, Integrated Environmental Covenants arose as a result of consultation under the target group approach (TGA). They constitute one policy measure aimed at achieving the targets of the 1989 National Environment Policy Plan (NEPP). The TGA resulted from the recognition of the need for cooperation between different sectors of society to achieve the 200 plus quantifiable targets of the NEPP. In particular, the Government perceived that the necessary improvements in industrial performance would be more easily achieved by obtaining industry's commitment to solving problems and by using their expertise. The Government considered traditional command-and-control measures as insufficient for meeting the ambitious NEPP targets.⁽²⁹⁾

The Declaration on the Implementation of Environmental Policy in the Netherlands Chemical Industry (DIEP)⁽³⁰⁾ was the second covenant to be signed under the target group approach. It is viewed as one type of policy measure to help achieve the Government's Integral Environmental Target Plan for the Chemical Industry (IETP) relating to environmental pollution caused by the chemical industry in the Netherlands. The Declaration covers all segments of the industry except for the paint, lacquer, varnish and printing industries, pharmaceuticals companies and soap and cosmetic manufacturers. In 1997, 149 companies fell into these categories, of which about ten were large multinationals; 126 companies are signatories to the Declaration, and according to the VNCI, the Dutch Chemical Industry Association, three companies were complying with the terms of the agreement without being signatories (117 of the companies are members of the VNCI, which is itself a signatory to the Declaration).⁽³¹⁾

The EA offers signatory companies greater flexibility in complying with environmental regulations. All companies whose corporate environment plan is approved by the licensing authorities benefit from greater flexibility in planning environmental investments and from a simplified licensing procedure.

• The impacts and activities covered are:
• climate change;
• acidification;
• diffusion (of environmentally hazardous substances to different environmental media and radiation);
• eutrophication;
• waste disposal (including soil);
• disturbance (noise, odour, external safety);
• company-based environmental management.

The targets set do not cover all emissions from chemical plants.

One of the EEA Report's six case studies dealt with the implementation of the Chemical Industry Declaration. Its assessment concluded that in terms of environmental improvement the Declaration earned the top rating "+++"; in terms of environmental effectiveness, it rated a "+/?" (slightly positive/uncertain outcome); and in terms of technical change it rated "+" (slightly positive).⁽³²⁾

Another example of a toxic emissions reduction initiative is the United States Environmental Protection Agency's EPA 33/50 Program.⁽³³⁾ The overall objective was to reduce the releases and transfers of 17 toxic chemicals. Using a 1988 baseline, the first goal was a 33 per cent national reduction for 17 chemicals by 1992 and a 50 per cent reduction by 1995. The data used to track progress came from the mandatory Toxics Release Inventory (TRI).

The EPA and chemical industry considered the 33/50 programme a success. It achieved overall reductions of 50.7 per cent in 1994, a full year ahead of the 1995 target. By that time, 757 million pounds of releases and transfers had been eliminated since the 1988 baseline year. The 1,300 companies participating in 33/50 were expected to continue reductions in 1995 and 1996. Releases of the 17 chemicals were reduced at nearly twice the rate of other TRI chemicals after 1991, when the programme began; 33/50 participants achieved their reductions at a much faster rate than other companies -- 50 per cent versus 30 per cent from 1991 through 1994, and 60 per cent versus 35 per cent after 1988.

The EPA cites the 33/50 programme as a groundbreaking non-regulatory initiative for reducing the releases and transfers of toxic chemicals. Representing a shift from the traditional command-and-control approach for lessening the risks associated with specific chemicals, the programme sought cooperation with industry rather than confrontation. The EPA identified the environmental goals and the preferable targets, while letting industry determine the best and most effective route for reaching the goal. As a result, environmental protection was achieved more rapidly and lower cost than would have been done in the absence of the programme.

To every newly committed company, the EPA provided a certificate signed by the EPA Administrator. The agency also profiled companies which achieved release and transfer reductions based on pollution prevention activities. Companies were able to use the EPA certificates for both internal and external purposes, which enabled them to demonstrate to their own staff and to the local communities where they operated that environmental protection was taken seriously. Whilst stating that participation in the 33/50 programme was not legally required, the EPA recognized that the data to measure the reductions came from the mandatory TRI. According to the EPA, the 33/50 programme is a non-regulatory initiative which was built upon, and received accountability from, a regulatory policy.⁽³⁴⁾

One shortcoming of the programme was the failure of some businesses to join the initiative. Out of approximately 8,000 eligible companies -- any company which submitted at least one TRI report for any of the 17 targeted chemicals -- 1,300 companies committed themselves to the programme. The participation rate for the 600 largest companies was over 60 per cent while the rate for SMEs was only 13 per cent. As the EPA concluded, what these statistics indicate is that, for future non-regulatory initiatives, EPA has greater hurdles to overcome with SMEs than with the larger companies.⁽³⁵⁾ Another issue concerned the limitations of TRI data. While the information from TRI formed the backbone of the programme, not all pertinent information was available from the database. Ascertaining the reasons for any decreases in releases and transfers is difficult. Reductions can result from pollution prevention activities, from end-of-pipeline practices, or merely from a slowdown in business. The usefulness of TRI data is limited further by the unavoidable time lag between the reporting year and the publication date.

Brazil provides an example of an environmental agreement in which trade unions and employers share responsibility. Chemical trade unions and employers in this country, in cooperation with the Government, have negotiated a National Accord for Accountability. The agreement provides detailed guidelines and procedures for the safe use of benzene. The arrangements provide for full participation of workers and their unions. The "Benzene Accord" was signed in 1995 by a total of 12 bodies drawn from industry, trade unions and government. In the Accord, a technical standard defines benzene as a carcinogen and provides a technological reference value that Brazilian workers, employers and government consider to be safe. Workers are given equal representation on a Permanent National Commission on Benzene to oversee developments, monitor compliance, promote studies, supplement laws and regulations, provide for alternative control measures and issue certificates for the controlled use of benzene. The Accord is administered at the plant level by a representative group of benzene workers (GTP) which has full responsibility for programmes, including worker training. Full employer cooperation with the GTP is required, including access to information and records and provision of office space and equipment, and heavy penalties are provided for violations.⁽³⁶⁾

EAs are also being widely used to improve energy efficiency. Hundreds of voluntary programmes around the world are successfully reducing greenhouse gas (GHG) emissions while increasing the competitiveness and efficiency of businesses and individuals in the countries in which they operate. The International Energy Agency (IEA) has identified more than 350 such voluntary approaches in operation today (IEA 1997).⁽³⁷⁾

The European chemical industry has been implementing a Voluntary Energy Efficiency Programme (VEEP) since 1992, in line with initiatives of the European Commission. VEEP 2005 is a unilateral commitment to reduce specific energy consumption by a further 20 per cent between 1990 and 2005, provided that no additional energy taxes are introduced. CEFIC stresses that this approach is fully in line with the RC programme and the principle of continuous performance improvement.⁽³⁸⁾

To address the problem of climate change, the German chemical industry has committed itself to a rational use of energy in chemical manufacturing as well as a rational use of energy through products of the chemical industry. In 1995, the German Chemical Industry Association (VCI), the German Chemical Industry Trade Union (IG Chemie) and the German Federal Ministry of Economic Affairs published a joint position paper on reduction of energy consumption and CO₂ in the chemical industry. Building on this joint work, and on the practical reductions in energy use already achieved, the German industry voluntarily committed itself to: (i) a reduction in specific energy consumption by more than 30 per cent during the period 1990-2005; and (ii) a similar reduction of energy-related CO₂ emissions during the same period.⁽³⁹⁾ However, the VCI adds the caveat that this self-commitment must not be counteracted by additional fiscal burdens or regulations.⁽⁴⁰⁾

The United Kingdom's Energy Efficiency Agreement between the Chemical Industries Association and the Government (Department of the Environment, Transport and the Regions) was signed in November 1997. It aims to reduce the chemical industries' specific energy consumption (energy/unit output) by 20 per cent of its 1990 level by 2005. In large part, this is seen as one way of helping both the Government and the chemical industry to meet their commitments under the United Nations Framework Convention on Climate Change (UNFCC). It is an example of a long-term agreement programme as a partnership between government and industry associations, and some individual companies, to increase energy efficiency.⁽⁴¹⁾

Voluntary agreements between firms and local authorities, to supplement and strengthen existing regulations, are also common in Japan. Some 40,000 such agreements have been concluded since 1970, many of them in the chemical industries (2,553 agreements were concluded in the one-year period between October 1991 and September 1992 alone and 198 of these were in the chemical industries). They are adapted to local conditions, and set standards that tend to be stricter than those in national or municipal regulations.⁽⁴²⁾

1.3.3. Environmental management schemes and standards

Some voluntary initiatives have government and industry participation, but with criteria, standards and certifying or auditing processes that are determined by a third party. Two such initiatives are reviewed in this report, namely the European Union's Eco-Management and Audit Scheme (EMAS), and the quality management and environmental management systems standards set by the International Organization for Standardization (ISO). Such initiatives are designed to support the implementation of environmental management systems and to enable companies to obtain external recognition of their systems either through third-party verification or self-declaration. Both apply to environmental management systems, but do not necessarily, especially in the case of the ISO, cover health and safety as well. The International Labour Office is currently carrying out a study on the advisability of developing a code of practice on occupational health and safety management systems. How such an ILO code would relate to EMAS and ISO environmental standards remains unclear at the moment (see section 1.4).

1.3.3.1. European Union Eco-Management and Audit Scheme

The European Union Eco-Management and Audit Scheme (EMAS) was established under European law by Council Regulation (EEC) No 1836/93 of 29 June 1993 and is implemented and administered nationally by EU Member States.⁽⁴³⁾ EMAS was established to improve the quality of environmental management throughout European industry, to help companies gain a competitive advantage from these improvements, and to communicate their progress to the general public. It is based on the premise that environmental management is a fundamental part of good management and is essential to any well-run business. Introduced in 1995, it is a voluntary scheme in which individual industrial sites register with their national EMAS authority. In order to participate in EMAS, companies agree to develop an environmental management framework and to implement each of the following steps at the relevant site:

(1) Company environmental policy. There must be a company-wide environmental policy before any individual site can be registered. The policy should be in written form and adopted at the highest managerial level. It should state the company's overall environmental aims and its commitment to continuous improvement (beyond compliance with minimum legislative requirements), and to compliance with relevant environmental regulations. The company must also establish a corporate overview and coordination system.

(2) Environmental review. This involves a comprehensive analysis of the inputs, processes and outputs at the site to identify the relevant environmental impacts and issues to be tackled by the site management.

(3) Environmental programme. This should be set out in accordance with the policy and review. The programme should list activities to achieve defined objectives which translate the policy's aims into specific quantified goals for improvement.

(4) Environmental management system. The system should define responsibilities, procedures and tools for implementation of the policy and programme. Companies wishing to register under EMAS may devise their own environmental management system, or use a recognized international standard such as ISO 14001.

(5) Environmental audit cycle. Periodic audits should be carried out whereby environmental practices and performance are checked against stated policy. There should be activities to assess whether the programme is being followed and if the management system is adequate, or if any changes are needed.

(6) Environmental statement. After the initial review and, generally, each subsequent year, a concise and comprehensible statement of environmental performance for the public should be drawn up and made publicly available by each participating site. The statement should include a summary of "significant environmental effects" -- consumption of raw materials, energy use, water use, emissions, hazardous wastes to land -- although this will often be aggregated data.

(7) Validation. The environmental statement must be validated by an EMAS-accredited, independent environmental verifier. The policy, programme, management system and audit procedure also have to be verified as conforming with the requirements of the scheme.

Training and EMAS

Annex IB.2 of EMAS sets out the training requirement for personnel whose work might have a significant effect on the environment. The usual practice is for all the workforce to receive basic training on environmental awareness. More in-depth and focused training is usually required for personnel who will be auditing the environmental management systems that are implemented. Annex IIC of EMAS states that "Environmental audits must be performed by persons or groups of persons with appropriate knowledge ... [and] ... sufficient training and proficiency in the specific skills of auditing to achieve the stated [audit] objectives".⁽⁴⁴⁾ Therefore, HSE training will be promoted as more and more companies sign on to EMAS.

1.3.3.2. International Organization for Standardization

The International Organization for Standardization (ISO) is a non-governmental, worldwide federation of national standards bodies established for the purpose of standardizing industrial operations across national borders and facilitating the international exchange of goods and services. Standards are documented agreements containing technical specifications or other precise criteria to be used consistently as rules, guidelines, or definitions of characteristics, to ensure that materials, products, processes and services are fit for their purpose. International standardization is market-driven, and therefore based on voluntary involvement of all interests in the marketplace.⁽⁴⁵⁾

Traditionally, the ISO's main work consisted of technical standardization, but in the 1980s it widened its mandate to work on "soft" management issues of total quality and environmental management. The two main products to date are:

(i) The ISO 9000 family of international quality standards and guidelines for establishing quality management systems. They represent an international consensus on good management practices with the aim of ensuring that an organization can consistently deliver the product or services to meet its clients' quality requirements. The standards provide organizations with guidelines on what constitutes an effective quality management system, and models against which this system can be audited to give the organization and its clients assurance that it is operating effectively. "ISO 9000 certification" means certification against ISO 9001, ISO 9002 or ISO 9003.⁽⁴⁶⁾

The ISO lists many advantages accruing to firms which comply with the ISO 9000 standards, including performance, coordination and productivity improvements, the opening up of new market opportunities and, for small and medium-sized firms, the opportunity to compete on equal terms with larger organizations. In many instances, bidding for potential contracts is limited to firms with ISO 9000 certification. An example of this is Sweden, where the Ministry of Labour gives preference to bidders for state-financed training contracts who have ISO certification for the training institutes which will deliver such training.

(ii) The ISO 14000 family addresses various aspects of environmental management. The first two standards, ISO 14001 and ISO 14004, deal with environmental management systems. These are management tools to enable an organization of any size or type to control the impact of its activities, products or services on the environment. An environmental management system represents a structured approach to setting environmental objectives and targets, to achieving these and demonstrating that they have been achieved. ISO 14001 "Environmental management systems -- Specification with guidance for use" specifies the requirements for such an environmental management system. There is a widespread expectation that ISO 14001 certification will be required for any large firm doing business internationally (and even nationally) within the near future.

The ISO uses the term "ISO 14000 certification" for the sake of consistency, although in practice only the ISO 14001 standard includes a model for environmental management certification, and organizations whose environmental management systems are certified are issued with an ISO 14001 certificate.⁽⁴⁷⁾

The ISO standards do not address health and safety. In 1997, the ISO decided against developing an international standard for occupational health and safety management systems (OH&S) which would have been compatible with the ISO 9000 and ISO 14000 series.⁽⁴⁸⁾ This decision was based on the outcome of an ISO international workshop on OH&S management system standardization in September 1996, which indicated that there was little support from the main stakeholders for ISO to develop international standards in this field.⁽⁴⁹⁾ This raises the issue of the integration of standards for management systems pertaining to environment and those for occupational safety and health.

Training aspects of ISO 9000 and 14000

Training is dealt with in the quality system requirements for ISO 9000 standards. The ISO defines the standard for training in the following terms:

The supplier shall establish and maintain documented procedures for identifying training needs and provide for the training of all personnel performing activities affecting quality. Personnel performing specific assigned tasks shall be qualified on the basis of appropriate education, training and/or experience as required. Appropriate records of training shall be maintained.

ISO 14001 defines the standard for training as follows:

The organization shall identify training needs. It shall require that all personnel whose work may create a significant impact upon the environment, have received appropriate training. It shall establish and maintain procedures to make its employees or members at each relevant function and level aware of:

(a) the importance of conformance with the environmental policy and procedures and with the requirements of the environmental management system;

(b) the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance;

(c) their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the environmental management system, including emergency preparedness and response requirements;

(d) the potential consequences of departure from specified operating procedures.

Personnel performing the tasks which can cause significant environmental impacts shall be competent on the basis of appropriate education, training and/or experience.

1.3.3.3. Industry acceptance of EMAS and ISO

German chemical firms have been at the forefront in seeking EMAS registration and have been encouraged by the VCI which sees it as complementary to Responsible Care (RC). In fact, the highest rate of participation anywhere in the world in both EMAS and ISO 14001 is to be found in Germany.⁽⁵⁰⁾ In 1997, 140 chemical sites had a verified EMAS system (up from 59 in 1996) and the number was expected to grow.⁽⁵¹⁾ The VCI also encourages its members to register their environmental management systems (EMSs) under ISO 14000. It estimates that by 2001, 80 per cent of its members will have an EMS based on ISO 14000. With such an EMS, companies that participate in RC may benefit from simplified licensing and inspection procedures required by authorities.⁽⁵²⁾ The same applies to EMAS. In 1997, the Bavarian Government and the chemical industry signed an environmental agreement giving EMAS-accredited companies more freedom in deciding how to implement and execute environmental management. Negotiations were under way in three other regions to come to similar agreements.⁽⁵³⁾

In order to help SMEs participate in RC and set up EMSs, the VCI started a pilot study in 1996 involving 19 companies. It entrusted its environmental advisory service with organizing the project which aims at preparing these companies for certification/validation under EMAS/ISO 14001 in an optimal manner.⁽⁵⁴⁾

The extent of EMAS and ISO accreditation has also been growing in the United Kingdom. The Chemical Industry Association reports that the proportion of its sites with formal or certified HSE management systems including EMAS and ISO had increased since 1994. By 1998 71 per cent of sites had formal or certified systems for the environment and 83 per cent for health and safety (the total number of sites is around 325); 11 per cent of sites had ISO 14001 or EMAS, whilst 60 per cent had formal, uncertified environmental management systems. The Association defines a "formal system" as a "comprehensive documented system for the control of the process in question -- this need not be an externally accredited system". The Association lists these "formal systems" as:

• Quality: ISO 9001/2/3, Good Laboratory Practice, International Quality Rating System, National Accreditation of Measurement and Sampling;
• Health and safety: International Safety Rating System, British Safety Council 5-Star;
• Environment: International Environment Rating System, ISO 14000, EMAS.

The CIA says that the formal process of risk assessment which has to be undertaken to achieve certification had undoubtedly had benefits for the companies involved. It adds that there is statistical, but as yet unpublished, evidence to show that these sites have a better safety performance than those with no formal management systems.⁽⁵⁵⁾

Auditor-verified, EMAS site environmental reports are a new source of information on training and education initiatives. For example, the 1997 EMAS report for DuPont's facility at Gloucester in the United Kingdom states:

All employees receive training in occupational HSE issues and they are provided with the necessary protective equipment where potential risks are identified. Auditing is a cornerstone of our QSHE [Quality, Safety, Health and Environment] management system ... During 1996, Gloucester Site achieved an Investors in People award. One of the key principles of this commitment is to regularly review training and development of all employees. In 1996, this concept included seminars on environmental awareness and our management system, to all site personnel including contractors.⁽⁵⁶⁾

The New Zealand Chemical Industry Council (NZCIC) says that uptake of ISO 9000 Series certification in New Zealand is second only to that in the United Kingdom. There is less enthusiasm for the ISO 14001 Series which is seen as a complex and relatively expensive means of implementing a recognized EMS. The New Zealand Responsible Care™ Management System recognizes ISO certification where appropriate. It also incorporates an EMS based on British Standard 7750 (BS7750) which includes a self-assessment process.⁽⁵⁷⁾

In 1994, chemical companies apparently led all other industries in the United States in gaining ISO 9000 certification with some 600 registrations, about 19 per cent of total registrations.⁽⁵⁸⁾

As of April 1997, 35 Indian companies were certified under ISO 14001, eight of which are in the public sector, and ten of which have an association with Western manufacturers. There is so far only one chemical company, Herdillia Chemicals, which is both a signatory to the RC programme and certified to ISO 14000. Furthermore, there is a preponderance of petroleum refineries, mining, and cement manufacturing units going in for ISO certification, while the RC participants are largely involved in the manufacture of base and intermediate chemicals and pharmaceuticals. ⁽⁵⁹⁾

Pharmaceutical firms in Yugoslavia are taking a concerted approach to implementation and certification of environmental management systems based on ISO 14000 standards. In 1997, the Yugoslav Association for Global Quality Approach -- YU Quality Forum organized the first Yugoslav Conference on Environmental Management in the Pharmaceutical and Cosmetic Industry which helped raise awareness about the relevance and benefits of the ISO 14000 series in developing environmental management systems.⁽⁶⁰⁾

1.4. The relationships between the VI schemes and standards

One of the oft-proclaimed benefits of VIs is that, being voluntary, they are designed in some measure to avoid the "costly and time wasting burden" of reporting on different regulations to different authorities. Nevertheless, the proliferation of different voluntary schemes and standards means that companies often find themselves carrying out multiple voluntary audits under the different schemes and collecting and reporting non-standardized data to a variety of non-statutory bodies. The industry has recognized the workload this creates for large companies as well as SMEs, as evidenced by CEFIC's position paper on Safety, Health, Environment and Quality (SHEQ) Management Systems and Management System Standards (box 1.3).

Boxes 1.4 and 1.5 explain the differences and relationships between the principal VIs (EMAS, ISO and Responsible Care).

In practice, the different initiatives tend to merge into each other and at company and/or plant level form part of an HSE management system. The HSE Director for the Association of the Chemical Industry of the Czech Republic (SCHP), for example, says that ISO, EMAS and RC are really part of a general environmental management system package, so that it is often impossible to separate out the individual elements. He adds, "If we try to separate RC, ISO 14000 and EMAS, it will create conceptual and practical problems, which could lead to difficulties with other manufacturing sectors which don't have RC-type initiatives and so naturally concentrate on ISO 14000 and EMAS. There is a need to harmonize the RC initiative with other sectors of industry to avoid their jealousy."⁽⁶¹⁾
 

Box 1.3 Safety, Health, Environment and Quality (SHEQ) Management Systems and Management System Standards

In general, chemical companies have used a variety of systems for managing and improving SHEQ performance. This approach is recognized by many organizations as not being cost-effective. CEFIC fully supports the view that companies should implement, develop and strengthen SHEQ management systems. Such systems, when appropriately applied, are achieving, maintaining and demonstrating SHEQ control and improvement. Management systems support the chemical industry's Responsible Care initiative. Integrated management systems are based on common core elements, designed to manage and coordinate the requirements of several management control systems such as safety, health, environment or quality. Core elements include: Definition of policies, objectives and targets. Management of resources (ie. people, material and equipment). Identification of stakeholder requirements. Planning and prioritization. Business and operational process management. Monitoring and evaluation of performance, including corrective action. Management review (of performance effectiveness, improvement needs). The purpose of having an integrated system is to provide clear direction and effective allocation of resources at the lowest possible cost. This helps business functions to perform effectively together in pursuit of the organization's business goals. CEFIC supports the integration of internal SHEQ management systems where this is efficient and effective for an organization. Before the development of any SHEQ management system standard there should be clear justification of the benefits, in order to avoid unnecessary proliferation. Any new or revised standard must be compatible, and thus integratable with, existing management system standards. Consolidation of existing standards should take priority over the development of new standards.

Source: Position Paper on Safety, Health, Environment and Quality (SHEQ) Management Systems and Management System Standards (Brussels, CEFIC, 09.04.98).

 

Box 1.4 The main differences between EMAS and ISO 14001

EMAS requires continual improvement of environmental performance with a view to reducing environmental impacts to levels not exceeding those corresponding to economically viable application of best available technology (EVABAT). In ISO 14001, EVABAT is only an option that companies may consider. Auditing of environmental performance is an EMAS requirement, whereas in ISO, assessment of performance is covered under monitoring and measurement and management review. EMAS requires publication of an environmental statement with a specified content. ISO does not have any public information disclosure requirements. Registration to EMAS requires third-party verification of the environmental statement and the environmental management and auditing system by accredited professional validators. ISO allows for third-party certification, by whom is not specified, of the environmental management system or self-declaration of conformance. Furthermore, compliance is encouraged in EMAS because the European Union retains the right to issue directives if self-regulation is ineffective.

Source: CEFIC -- The relationship of Responsible Care with EMAS and ISO 14001 (Brussels, 1997).

 

Box 1.5 The relationship of Responsible Care with EMAS and ISO 14001

CEFIC and the ICCA argue that Responsible Care is a much wider concept and programme than either EMAS or ISO 14001. The two organizations state that: "The requirements of EMAS and ISO 14001 are consistent with part of the Responsible Care commitment ... It should be clearly recognized that Responsible Care is much broader in scope. Safety and health are not specifically included in EMAS and ISO 14001 ... As internationally recognized schemes for environmental management both EMAS and ISO 14001 potentially provide added value with respect to the environmental commitments of Responsible Care. By, for example, acting as a reference point with respect to environmental management systems under Responsible Care." CEFIC suggests that "... the management system requirements of EMAS and ISO 14001 could be viewed as potential 'codes of practice' to be used within Responsible Care". In order to fulfil the Responsible Care commitment, CEFIC recommends its members to implement and/or improve their safety, health and environmental management systems, building on existing company systems and activities. "When implementing these systems, CEFIC recommends to take into account the environmental management system requirements of EMAS and ISO 14001."

Source: CEFIC -- The relationship of Responsible Care with EMAS and ISO 14001 (Brussels, 1997).

* * *

For several reasons, voluntary initiatives are becoming more important as means to promote good health, safety and environment performance in the chemical industries as elsewhere. Although this approach does not eliminate the role of government regulation, it does tend to be accompanied by a shift away from "command-and-control" type regulation. Although not precisely defined, the term "voluntary initiatives" is taken here to comprise company and industry-wide initiatives, government-industry environmental agreements, and environmental (or HSE) management systems. The evidence is mixed, but there is some reason to believe that the development of voluntary initiatives such as Responsible Care has led the public in some countries to take a less negative view of the chemical industries. Environmental agreements -- bilateral agreements between industry and government -- have been widely developed in western Europe and have been used for some purposes in the United States. Formal environmental management systems form another significant class of voluntary initiatives. The main examples are EMAS in the European Union and the ISO 14000 standard. Increasing numbers of firms and sites are being certified under one or both of these schemes. Corporate HSE reports represent yet another kind of voluntary initiative that is gaining in importance. Although there are identifiable differences between these voluntary initiatives, there is considerable scope for integrating them at company and plant level so as to minimize confusion and duplication in reporting requirements.

Notes

1.  UNEP: Voluntary Industry Codes of Conduct for the Environment (Paris, Industry and Environment Office, 1998), Technical Report No 40, p. 7.

2.  UNEP: Voluntary initiatives for responsible entrepreneurship: A questions and answers guide (Paris, Industry and Environment Office).

3.  Florian Wegleitner: Responsible Care -- ein Vergleich zwischen Oesterreich und England (Vienna, Austrian Chemical Industry Association, 1997), available in German only.

4.  UNEP: Voluntary industry codes of conduct for the environment (Paris, Industry and Environment Office, 1998), Technical Report No. 40, p. 7.

5.  ibid., p. 4.

6.  UNEP: Reducing greenhouse gas emissions: The role of voluntary programmes (Paris, Industry and Environment Office, 1997), p. xii.

7.  European Commission Directorate General III.01 -- Industry: Study on voluntary agreements concluded between industry and public authorities in the field of the environment -- Final report (Brussels, 1997), Executive Summary.

8.  G. Liardet: "Public opinion and the chemical industry", in Chemistry and Industry magazine (London, 18.02.91), pp. 118-123.

9.  Uncertain progress for Responsible Care (London, ENDS Report 233, June 1994), pp. 16-18.

10.  What's wrong with Responsible Care? (London, ENDS Report 259, Aug. 1996), p. 20.

11.  ibid.

12.  "Europe begins to measure performance", in Chemical Week (Washington, DC, 1-8 July 1998), p. 111.

13.  "Responsible Care: The second phase", special issue of Chemical Week magazine, United States, 7/14 July 1993.

14.  ibid.

15.  United States Chemical Manufacturers' Association: Responsible Care progress report 1997 (Washington, DC, 1998), p. 10.

16.  United Nations: Earth Summit Agenda 21 -- The United Nations Programme of Action from Rio (New York, UN Department of Public Information, 1992).

17.  ICCA: Position paper on sustainable development and the chemical industry (Arlington, United States, 1996), p. 2.

18.  "Germany: Regulation or volunteer action?", in Chemical Week (London, 1-8 July 1998), p. 125.

19.  ICCA: Responsible Care status report (Arlington, United States, 1996), p. 13.

20.  European Environment Agency: Environmental agreements -- Environmental effectiveness (Copenhagen, 1997), Environmental Issues Series No. 3, Vol. 1, Executive Summary, p. 11.

21.  ibid.

22.  ibid.

23.  European Union: Communication from the Commission to the Council and the European Parliament on Environmental Agreements COM (96)561 (Brussels, 1996).

24.  European Commission Directorate General III.01 -- Industry: Study on voluntary agreements concluded between industry and public authorities in the field of the environment -- Final report (Brussels, 1997), Executive Summary.

25.  European Union: Communication from the Commission to the Council and the European Parliament on Environmental Agreements COM (96)561 (Brussels, 1996).

26.  ibid.

27.  European Environment Agency: Environmental agreements -- Environmental effectiveness (Copenhagen, 1997), Environmental Issues Series No. 3, Vol. 1, Executive Summary, p. 11.

28.  "German report warns of unenforceable agreements", in European Chemical News (Brussels, 12-18 Aug. 1996), p. 43.

29.  European Environment Agency: Environmental agreements -- Case studies (Copenhagen, 1997), Environmental Issues Series No. 3, Vol. 2, p. 55.

30.   Declaration of Intent on the Implementation of Environmental Policy for the Chemical Industry (The Hague, 2 Apr. 1993).

31.  ibid.

32.  European Environment Agency: Environmental agreements -- Environmental effectiveness (Copenhagen, 1997), Environmental Issues Series No. 3, Vol. 1, Executive Summary, p. 13.

33.   John Harman: The United States Environmental Protection Agency 33/50 Program (Paris, OECD, 1997), in Proceedings of the OECD Workshop on Non-Regulatory Initiatives for Chemical Risk Management, OECD HS Publications, Series on Risk Management No. 7, pp. 37-43.

34.  ibid.

35.  ibid.

36.  "Globalisation will hamper sustainability, say trade unions", in Careline (London, April-June 1998), Issue No. 11.

37.  UNEP: Reducing greenhouse gas emissions -- The role of voluntary programmes (Paris, Industry and Environment Office, 1997), pp. xii.

38.  CEFIC: Voluntary energy efficiency programme VEEP 2005 (Brussels, Nov. 1997).

39.  VCI: Self-commitment for the energy sector (Frankfurt, 1996).

40.  VCI: Contribution of the chemical industry to climate protection in the energy sector: Reduction of specific energy consumption and CO₂ emissions (Frankfurt, undated).

41.  CIA: The Energy Efficiency Agreement (London, 1997).

42.  OECD Observer, No. 189, Aug.-Sep. 1994, pp. 8-11.

43.  Council Regulation (EEC) No 1836/93 of 29 June 1993 allowing voluntary participation by companies in the industrial sector in a Community eco-management and audit scheme.

44.  ibid., Annex IIC.

45.  ISO: Compatible technology worldwide (Geneva, 1994), p. 12.

46.  ISO: Publicizing your ISO 9000 or ISO 14000 certification, Geneva, Switzerland, p. 3.

47.  ibid.

48.  International Organization for Standardization: ISO decisions on OH&S, integration of ISO 9000 and ISO 14001, and information privacy (Geneva, 1997), ISO Press Release, Ref. 738.

49.  International Organization for Standardization: Spotlight, looking before leaping: ISO Workshop on Occupational Health and Safety, Geneva, ISO Bulletin 11/96.

50.  "Germany -- Regulation or volunteer action?", in Chemical Week, 1-8 July 1998, p. 125.

51.  CEFIC: Annual Responsible Care Report 1997 (Brussels, 1998), p. 11.

52.  "Europe begins to measure performance", in Chemical Week, 1-8 July 1998, p. 112.

53.  "Germany -- Regulation or volunteer action?", in Chemical Week, 1-8 July 1998, p. 125.

54.  VCI: Responsible Care report 1997 (Frankfurt, 1997), pp. 11-12.

55.  CIA: UK indicators of performance 1990-97 (London, 1998), pp. 25-26.

56.  DuPont Nylon: Environmental report 1997, Gloucester Site, United Kingdom (Gloucester, 1997), p. 15.

57.  New Zealand Chemical Industry Council (NZCIC): Personal communication from Barry Dyer, CEO, NZCIC, 21.07.98.

58.  Ann Thayer: "Chemical companies see beneficial results from ISO 9000 registration", in Chemical and Engineering News, 25.04.94, p. 10.

59.  ILO: Responsible Care in the chemical industry in India, A Status Report, Geneva, 1998, pp. 20-21.

60.  Franja Coha: Concerted approach to ISO 14000 by Yugoslav pharmaceutical firms, ISO 9000 News 6/1997 (Geneva, 1997), p. 28.

61.  Personal interview on 04.02.98 with Mr. Ivan Zika, SCHP RC Coordinator, Prague, Czech Republic.

2. Chemical industry initiatives

Voluntary HSE programmes developed by the chemical industries at international level comprise one general effort and other more specific programmes covering particular subsectors. The general effort, Responsible Care (RC), is the broadest and has attracted the largest share of attention and resources. It is the chemical industries' own worldwide initiative to continuously improve HSE performance. This has led some subsectors to create similar programmes. Chemical distributors and traders and chemical industry associations have established "partnership agreements" which allow each party to develop its own, specific RC programmes while using a common RC logo. In some cases distributors have developed their own Responsible Distribution initiative. This is also the case with the coatings industry. Finally, the Global Safe Use Initiative is the training-oriented effort of the pesticide manufacturers.

Whilst different programmes exist, the industry associations guiding the respective initiatives are at pains to stress that their individual programmes are all working towards the same broad goals of improving company HSE performance nationally and internationally, on the basis of greater public openness, public tracking and, in some instances, third-party verification. Indeed, at the national level there are often partnership agreements which recognize "compatibilities" or "equivalencies" between the schemes, meaning that performance improvement in one scheme will be mutually recognized in another.

A crucial difference between the initiatives is that whilst RC is international in coverage, the details of its content vary across its 40-odd national programmes. Whilst common objectives, guiding principles and approaches exist, national codes of practice, implementation plans and even performance indicators differ, and there is no one international RC programme which is uniformly implemented by national associations and by companies. By contrast, the Responsible Care/Responsible Distribution programme of ICCTA is international and based on a generic programme which is itself based on the American and European processes. It uses common standards and codes of practice with performance criteria which vary only as they embrace respective national legislation, associations and companies. Coatings Care is similar. The various initiatives are also at different stages of development and have different emphases. Responsible Care is the most advanced, having started in the 1980s. Responsible Distribution was begun in the early 1990s, and Coatings Care was only being developed in the late 1990s. The pesticide industry's Global Safe Use Initiative and its three safe use pilot projects, which are training-based, date from 1991. Similarly, within the individual initiatives, the regional and national programmes are at different stages of evolution and this is most clearly illustrated by RC.

2.1. Responsible Care

Responsible Care (RC) is the worldwide chemical manufacturing industry's voluntary commitment to continuous improvement in all aspects of HSE performance and to openness in communication about its activities and achievements.⁽¹⁾ It is described as the basis of significant cultural change within the chemical industry which is leading to improved performance and new levels of openness with the public.⁽²⁾

The International Council of Chemical Associations (ICCA)⁽³⁾ says that:

The global chemical industry believes that the key to improving the performance of the industry is both its commitment to achieving environmentally sound sustainable development and improved performance and transparency. Under the concept of "Responsible Care", chemical companies are committed, in all aspects of safety, health and protection of the environment, to seek continuous improvement in performance, to educate all staff and work with customers and communities regarding product use and overall operation. Through these efforts the industry is improving its efficiency, reducing risks to health and the environment and making better products which, in turn, help individual and industry customers.⁽⁴⁾

The industry argues that these features make Responsible Care a powerful programme for sustainable development. "The global chemical industry, as represented by the International Council of Chemical Associations (ICCA), views Responsible Care as a practical and visible tool for meeting its obligation to safely manage the risks associated with the ever-widening range of chemical production and products."⁽⁵⁾ The industry stresses the ethical aspects of RC and the fact that it is a new way of doing business. It emphasizes that whilst RC is not itself a management system, it needs a management system(s) for implementation.

In a progress report to the Intergovernmental Forum on Chemical Safety (a body set up to give effect to UNCED's Agenda 21), ICCA says that:

The global chemical industry intends to use Responsible Care as proof that voluntary industry initiatives which focus on flexibility and innovation can successfully complement appropriate regulation to succeed where command-and-control schemes have failed. Resource-strapped governments in both the developed and developing worlds are seeking new paradigms for environmental protection. Responsible Care is a partial answer to this search and its implementation will enable the chemical industry to make progress in reducing chemical risks.⁽⁶⁾

2.1.1. Structure of RC

ICCA and its Responsible Care Leadership Group (RCLG)⁽⁷⁾ now coordinate an international programme which since 1985 has been adopted by chemical associations and their member companies in 40 developed and developing countries. In 1996, these member companies accounted for approximately 86 per cent (by production volume) of world chemicals production.⁽⁸⁾ Regional industry associations also play an important role, and RC implementation is, for example, a condition of membership of the European Chemical Industry Council (CEFIC)⁽⁹⁾ and of the United States Chemical Manufacturers' Association (CMA). National chemical industry associations are responsible for the detailed implementation of RC in their countries.

Each national RC programme must incorporate eight fundamental features, as outlined by ICCA:

• a formal commitment on behalf of each company to a set of guiding principles signed, in the majority of cases, by the chief executive officer;
• a series of codes, guidance notes and checklists to assist companies to implement the commitment;
• the progressive development of indicators against which improvements in performance can be measured;
• an ongoing process of communication on health, safety and environmental matters with interested parties outside the industry;
• provision of forums in which companies can share views and exchange experiences on implementation of the commitment;
• adoption of a title and logo -- which clearly identify national programmes as being consistent with and part of the concept of Responsible Care;
• consideration of how best to encourage all member companies to commit and participate in Responsible Care;
• systematic procedures to verify the implementation of the measurable (or practical) elements of Responsible Care by member companies.

In addition to the key features, there are RC guiding principles for associations and especially companies. These principles express a commitment on the part of companies to support the continuous effort towards improvement of the industry's responsible management of chemicals. The following formulation is that of the Plastics and Chemicals Industries Association (Australia):

(1) to recognize and respond to community concerns about chemicals and our operations;
(2) to operate our plants and facilities in a manner that preserves the environment and protects the health and safety of our employees and the public;
(3) to develop and produce chemicals that can be manufactured, transported, used and disposed of safely;
(4) to give health, safety and environmental considerations priority in our planning for new products and processes;
(5) to report information on relevant chemical-related health or environmental hazards promptly to appropriate authorities, employees, customers and the public and to recommend protective measures;
(6) to give advice to customers on the safe use, transportation and disposal of chemical products;
(7) to increase knowledge by conducting and/or supporting research on the health, safety and environmental effects of our products, processes and waste materials;
(8) to cooperate with customers, authorities and affected groups and individuals to resolve problems created by the handling and disposal of chemical substances considered hazardous;
(9) to cooperate with government in developing laws and regulations to safeguard the community, the workplace and the environment; to endeavour to ensure that such laws are based on scientifically supported data and/or expert opinion;
(10) to promote these principles and practices by sharing experience and offering assistance to others who produce, handle, use, transport or dispose of chemicals.

The guiding principles are put into effect through RC management codes of practice (COP) -- or the equivalent guidance -- of which there are currently six (though individual national associations may well have more codes). They are:

• community awareness and emergency response;
• process safety;
• pollution prevention;
• distribution/transportation;
• employee health and safety;
• product stewardship (see section 3.4.2).

RC also provides for the formation of public advisory panels on the community and national levels, though this provision has not been put into effect in all countries. These panels are composed of diverse groups of individuals who provide the chemical industry with insight on performance improvement.

RC companies conduct or are moving to regular, usually annual, self-assessments of their progress on each of the management codes of practice. Some companies and national associations have gone further and their progress is validated/verified by a professionally qualified third party and the results, in some instances, are made available to the public.

2.1.2. Status of RC development worldwide

RC programmes in different countries are in different states of development and have different emphases, and their HSE training and education needs and activities vary accordingly.

Responsible Care originated in Canada in 1985 through an initiative by the Canadian Chemical Producers' Association (CCPA) to develop a set of guiding principles for environmental management, as referenced in an earlier ILO report.⁽¹⁰⁾ There had been little discussion of a similar programme in the United States but all that changed after the chemical disaster in Bhopal, India in December 1984. In response, the United States Chemical Manufacturers' Association (CMA) first set up its community awareness and emergency response (CAER) programme based on the realization that few of its members had emergency plans that addressed what should happen outside a plant or detailed coordination with local emergency services. From there, CMA began to work to shift RC from a statement of principles to a defined guide for improved practice -- incorporating programmes such as CAER -- that led to the six management codes of practice. Those codes included community outreach. The CMA formally adopted the RC programme in 1988 and commitment to the programme is, as with the CCPA, a condition of membership.

In terms of implementing the COPs, both the Canadian and American RC programmes are generally well advanced. For both programmes, what is variously described as a "sticky issue"⁽¹¹⁾ or "tough sell"⁽¹²⁾ is currently the issue of third-party verification designed to meet the industry's "don't trust us, track us" pledge. In Canada, verification began in 1995 with about a dozen companies, and a second round of verifications is currently under way. As of June 1998, CCPA's four-person independent team had verified that 44 CCPA members had "practice-in-place" (i.e. implemented for all 152 elements of RC). In a few cases, the CCPA verification team found items the companies needed to address, but there were no major problems.⁽¹³⁾ CMA's verification programme lost some momentum in 1996 when, against the recommendation of its RC National Advisory Panel, it bowed to the wishes of some members that results of third-party verification not be publicly disclosed.⁽¹⁴⁾ In its 1997 RC report, the CMA stated that 27 of its 190 member companies had participated in its management systems verification.⁽¹⁵⁾ By the end of 1998, CMA's members will have to certify that they have practice-in-place for the Distribution COP of RC.

Both CCPA and CMA are working with the Mexican Chemical Industry Association (ANIQ) on RC implementation, especially on the Distribution/Transportation COP. In 1997, CMA sponsored three distribution code workshops followed by a joint conference with CCPA and ANIQ in early 1998.⁽¹⁶⁾

From North America, RC spread to Europe. The United Kingdom's CIA was the first European national chemical industry association to adopt RC in 1989. This was followed by a European-wide initiative by CEFIC. RC has now been adopted in 21 countries in Western, Central and Eastern Europe. Enthusiasm, however, has varied -- some associations and companies have strong RC programmes, others less so. There has often been a "we all do this anyway" approach. The result has been that some companies call it HSE, some call it environmental management systems, some call it RC. Some observers feel there has been a lack of leadership in Europe in contrast with North America where RC has had a much higher profile. It was, for example, slow to be implemented in a serious way in Germany. In 1997 the German Chemical Industry Association (VCI) established an RC committee and since then much of the groundwork of RC has been done. However, VCI's RC coordinator believes that the initiative is not yet fully established in Germany. Large companies and firms with American parent companies are more active in Germany, while for many SMEs, RC remains difficult to implement.⁽¹⁷⁾ The VCI is helping such companies through workshops and special implementation guidelines. Trade unions are also involved in educating employees. In 1996 VCI and the German chemical distribution association signed an RC partnership agreement.

There is also a narrow company base in some Central and Eastern European countries, whose associations joined before new membership criteria were introduced. Only 12 companies, representing some 75 per cent of Polish chemical production by sales value, have joined the RC programme coordinated by the Polish Chamber of the Chemical Industry (PIPC), which began in late 1992. In 1996, an RC programme secretariat was established in Poland. The Chamber says that the RC programme is perceived as an initial step towards integrated HSE management in Poland.⁽¹⁸⁾

CEFIC, through its RC committee, has played a central role in the development of RC in Europe and, in addition, has been acting in 1997-98 as the ICCA secretariat. Product stewardship is an area where CEFIC is increasing its efforts. By the end of 1998, it also hopes to have a concrete tool to measure what the European chemical industry has achieved through RC. To this end, it has developed a pan-European set of indicators of performance (see section 2.1.5). Using the indicators, member associations will survey their performance in 16 HSE areas and collect these data for publication by CEFIC in the next five years. Federations will use the new CEFIC guidance for federations on RC implementation to promote self-assessment through the companies. Some associations are going further than self-assessment.

By 1991, RC had spread to Japan, Australia and New Zealand. Adherence to Responsible Care is a condition of membership of the Australian Plastics and Chemicals Industries Association (PACIA). The 107 companies currently participating in the RC programme account for over 80 per cent of Australia's $17 billion annual turnover in chemicals.⁽¹⁹⁾ The Association states that:

The Responsible Care programme has resulted in a substantial impact on the HSE skill levels and performance of most companies and employees in the Australian chemical industry. However, owing to the limited priority given to publicity, combined with rising community expectations, there has been little impact to date on the general community understanding and assessment of the risks of chemical use.⁽²⁰⁾ PACIA is now thinking about relaunching RC to bring in new energy and ideas.⁽²¹⁾

As in Germany, the RC programme of the Japan Chemical Industry Association (JCIA) got off to a slow start in 1990, although it picked up momentum with the creation of the Japan Responsible Care Council (JRCC) in 1995. As of July 1998, the JRCC had 101 participating companies, accounting for more than 75 per cent of Japanese chemical production. Trade unions also participate in RC activity at both industry level and enterprise level. They have been working to improve their members' awareness of RC by disseminating relevant information (such as the results of negotiations with employers on this topic) in union periodicals.

In 1992, RC programmes started up in Brazil and Mexico. Programmes have subsequently been launched in Argentina, Chile, Colombia and Peru.

In the Asia-Pacific region, implementation is at an early stage for the Philippines, India, Malaysia, Singapore and Hong Kong and Taiwan, China. Thailand is currently applying for membership of ICCA's Responsible Care Leadership Group (RCLG). Implementation in the region is moving at varying speeds and with widely differing levels of company support.

Creating the Taiwan Responsible Care Association (TRCA) in 1994 took approximately two years and a sustained effort, on the part of executives from nine companies representing an entire industry, to develop the necessary materials and education tools. TRCA acknowledges that implementing RC will be an enormous task for it. According to the Association, in numerous firms there is a lack of professional knowledge and training about RC. It says, however, that the initiative is moving ahead rapidly, with members now seeking greater cooperation in many areas such as shared contractor training programmes and performance reporting standards.⁽²²⁾ It says that one of the lessons learned is that the development of RC in Taiwan, China "will require taking risks and increasing education on a large scale".⁽²³⁾

In India, on the other hand, the Indian Chemical Manufacturers' Association (ICMA) reports that RC in India has been slow to gain acceptance from the chemical industry since it was adopted in 1993. As of 1997, only 17 per cent of the Association's members had joined the programme, and as of 1998 ICMA had not yet permitted the RC logo to be used by anyone.⁽²⁴⁾ The Association believes many large Indian chemical producers are adopting a wait-and-see attitude towards RC. They want to make sure the programme is voluntary and that it will have concrete benefits. While the Association stresses that RC is a voluntary programme, there is a feeling among producers that they are being forced to show a greater concern than producers in other countries about HSE management issues because of the legacy of Bhopal.⁽²⁵⁾

In Africa, two national associations have adopted RC, one in South Africa and the other in Zimbabwe. Morocco is currently applying for membership of ICCA's RCLG. Since 1994 the South African Chemical Industry Association (CAIA) has had an active RC programme, which it believes has done much to raise HSE awareness in both the chemical and support industries, particularly among SMEs. The Association is currently (July 1998) carrying out a pilot project to develop quantitative indicators of performance.⁽²⁶⁾

No information was available to the ILO concerning the possible introduction of Responsible Care or other industry initiatives into the countries of the Commonwealth of Independent States (CIS).

The RC Leadership Group (RCLG) was established in 1991⁽²⁷⁾ to coordinate RC activities at the international level. Its membership is drawn from the permanent members of the ICCA. In addition, its annual meetings can be attended by representatives from those countries which do not have Responsible Care programmes but who are associate members of the ICCA. It has now laid down RC membership and endorsement criteria as laid out in box 2.1. The RCLG is now planning to set up teams to coordinate:

• RC implementation;
• global communications;
• global performance indicators;
• RC membership.⁽²⁸⁾

Internationally, the chemical industry has raised awareness of its voluntary efforts through ICCA presentations on RC in international forums and meetings. It made its first major international presentation of the programme to the meeting of the Intergovernmental Forum on Chemical Safety (IFCS), the political forum charged with overseeing the implementation of UNCED Agenda 21 (Chapter 19 on the environmentally sound management of toxic chemicals)⁽²⁹⁾ in February 1997 in Ottawa, Canada,^(30),(31) thus bringing it to the attention of some 120 governments and other stakeholders worldwide. ICCA will be making an RC progress report to the next IFCS meeting in December 1998 in Japan. Similarly, in 1997, to promote RC, ICCA participated in several events at the United Nations General Assembly's Special Session on Rio +5, which was held to evaluate progress on Agenda 21 five years after the UNCED Earth Summit.⁽³²⁾

ICCA prepared a special RC status report for the IFCS meeting in 1997. Its summary states:

Because of RC, all types of chemical companies have publicly committed themselves to responsible HSE management. That commitment is changing the industry culture and affecting the industry's stakeholders in the form of reduced emissions to the environment, improved emergency response, fewer transportation mishaps, improved outreach and communication, safer working conditions and overall reduced risk. These improvements are not restricted to one part of the world but are occurring wherever RC is being implemented.⁽³³⁾

ICCA made an input to the 1998 session of the Commission on Sustainable Development (CSD), the United Nations body charged with monitoring implementation of Agenda 21. The theme of the session was "Responsible Entrepreneurship" (a term coined by the World Business Council for Sustainable Development and the International Chamber of Commerce), of which RC was indicated as an element. Commenting on the theme of Responsible Entrepreneurship, the International Confederation of Free Trade Unions (ICFTU) said that trade unions prefer the title "Responsible Leadership for Change" as it accommodates the idea of shared responsibility with other parties in the workplace and community; trade unions wanted and expected business to take a leadership role, but they also expected to work collaboratively to ensure that this leadership becomes effective.⁽³⁴⁾

2.1.3. Employee and public recognition of RC

Corporate HSE systems have been described by an ICI Group HSE systems development manager as "a cocktail of all the RC/ISO/EMAS requirements plus the companies own requirements, including legal obligations".⁽³⁵⁾ This "cocktail" means that at plant level, it is difficult to know whether a particular HSE outcome is the result of the company's commitment to RC.
 

Box 2.2 How do companies implement Responsible Care? One manager's view

1. RC starts as a value-based, ethical initiative. 2. It is then translated into guiding principles, codes of practice, etc. ,for management activities and systems. 3. These new management activities are then integrated into existing corporate HSE systems, so that these corporate HSE systems end up as a "cocktail". 4. The result in Europe has been that at least in big companies, RC often loses its identity at plant level and becomes part of the corporate HSE system. Locally, one cannot categorically state that a given HSE improvement is the result of an RC management principle or activity. 5. The consequence, therefore, is that the European chemical industry has lost much of the value of having an RC logo-RC language as these are not used by workers and management in plants.(36)

In some companies the "cocktail effect" is compounded by lack of employee recognition of and familiarity with RC. In many companies, the RC logo and language used at corporate level to present continuous improvements in performance to the outside world is not the same as that used at plant level by site management and workforce. Many European companies, in particular, do not use the RC terminology or trademark when communicating with their employees on HSE performance.

For many companies the problem appears to be a clash between corporate culture and the industry-wide RC HSE programme. A comparative study⁽³⁷⁾ of RC implementation in Austria and the United Kingdom found that in the latter, RC was effectively communicated only at management level, with the result that there was little motivational benefit for the general workforce. In Austria, by contrast, there had been greater efforts to involve the workers. In the United Kingdom, the Chemical Industries Association (CIA) confirms the weak link in terms of integration of RC into HSE training and communication at the company level. However, whilst the CIA's RC coordinator acknowledges that there is a poor HSE-RC branding correlation, he believes this is balanced by a strong HSE-EMS correlation.⁽³⁸⁾ The Association does, however, realize the need for greater worker recognition of, and involvement in, RC activities.

An industry survey by the Italian Chemical Industry Federation (Federchimica) shows that barely 25 per cent of industry employees have any experience of the programme, reflecting the fact that few companies are using RC as a framework for corporate HSE activities.⁽³⁹⁾

A 1996 CEFIC survey indicated that fewer than 30 per cent of its members wanted to use the Responsible Care logo, whereas CEFIC states that around 50 per cent of its company members actually use it. In Europe, RC also suffers from very low public recognition. According to the survey, less than 1 per cent of the general public have heard of it.⁽⁴⁰⁾

The poor HSE-RC correlation in many European companies is reflected in other parts of the world. The technical affairs director of the Brazilian Chemical Industry Association (ABIQUIM) says that "the companies most advanced in RC implementation [in Brazil] are United States multinationals, and that "European multinationals have good health, safety and environment standards here, but they don't have Responsible Care. They need a method for linking all their efforts with [the programme]." Seventy per cent of the Association's 133 members have adopted the programme which as of 1998 is a condition of membership. The remainder are mostly smaller companies that need help with financial, technical and human resources to implement RC.⁽⁴¹⁾

Various reasons are given by companies for not using the RC logo and language inside plants. They argue that their HSE programmes are within the spirit and guiding principles of RC but feel that using RC language may confuse the workforce by adding new terminology. A few companies actually decided to drop the words RC in HSE documentation for fear of confusing employees.⁽⁴²⁾ They also fear that by introducing what may appear to the workforce to be a new programme, they risk the accusation from employees of always chopping and changing programmes and failing to follow through on existing HSE initiatives. BP Chemicals in the United Kingdom, for example, supports RC but does not use RC language in its plants for those reasons. There is resistance at site management level to branding RC, and the company feels there would be negative reactions from site workforces if their current company HSE logo was changed in favour of RC. A company spokesperson, on the other hand, noted that the sales force is often more willing to talk RC as it gives them something new to discuss with customers.⁽⁴³⁾

Employee recognition would appear to be a problem also in other parts of the world. The South African Chemical and Allied Industries Association (CAIA) launched its RC initiative in 1994. It states that there is much good work being done by industry in HSE training, but not necessarily in the name of Responsible Care. A snapshot survey of some of CAIA's larger and more supportive members showed that most training is done in the name of HSE and ISO 14001 requirements with secondary reference to Responsible Care, rather than the reverse, so that awareness of the RC ethic is more common amongst supervisors and management than in the general workforce.⁽⁴⁴⁾

Similarly, in its RC compliance verification report, DuPont Canada notes that:

While good environmental practices are promoted through employee training and performance assessment processes, there is not that much emphasis on Responsible Care as an industry initiative or as an ethic. This also reflects an acknowledged need for more Responsible Care visibility below the senior management level in DuPont.⁽⁴⁵⁾

This contrasts, however, with Monsanto Canada's statement in its RC compliance certification report that:

Frontline employee involvement with RC® is significant right from the time of their orientation as new hires including the training program. Training is provided covering all aspects of environment, health and safety and the opportunity to make suggestions for improvement exists at all times. The Model Fair, sponsored by the environment and health team, generated 2,500 suggestions from employees. Prioritization has taken place through interviews with functional managers and supervisors and feedback provided to employees on resulting priorities.⁽⁴⁶⁾

Twenty-one other RC compliance verification reports from Canadian chemical companies, provided by the Canadian Chemical Producers' Association (CCPA) and reviewed as part of this report, confirm the Monsanto example. All these reports make statements to the effect that training is an important part of employee development and that RC figures as part of this training from orientation and induction courses for new employees onwards,⁽⁴⁷⁾ although the verification reports often make suggestions as to how the RC training component could be strengthened. In addition, Rhône-Poulenc Canada's RC compliance verification report from 1994 notes that the company "has attempted to keep Responsible Care visible by placing the Responsible Care logo on their tankage at Cooksville. Not only is this a reminder to employees, but it is also visible from near-by passing Go Trains".⁽⁴⁸⁾

Employee recognition seems to be relatively high and rising in the United States, according to a 1997 industry survey.⁽⁴⁹⁾ In July 1997, Market Directions, a national research firm, conducted a mail survey of over 23,000 employees at 78 CMA member companies, and there was a 48 per cent survey return rate. Since the baseline year of 1993 when employee awareness was 59 per cent, RC awareness had increased steadily to 83 per cent. The 1997 data showed that, of those employees aware of RC, 60 per cent felt they were familiar with the initiative. ⁽⁵⁰⁾

In another survey,⁽⁵¹⁾ this one of member companies, respondents repeatedly referred to the value that RC had brought to creating an integrated management system, making CMA members more efficient, particularly in the regulatory compliance arena. Comments from respondents included "RC has provided the platform to link environmental, health and safety with businesses ... Our employee, health and safety activities have been integrated with RC."⁽⁵²⁾ An article on RC in an American trade magazine supports the CMA statements, noting that, "To increase employee involvement, US companies are integrating RC with corporate or government HSE programmes. They are also extending the initiative from plant sites to all reaches of the corporation and adding RC goals to employee evaluation along with traditional measures such as sales growth or productivity."⁽⁵³⁾

However, lack of recognition of the RC programme was one of the concerns expressed by management systems verification auditors that inspected the Carollton and Wichita sites of Elf Atochem North America in 1997. Whilst acknowledging that the company had well-constructed HSE systems and was committed to the RC programme, the verification panel reported that employees did not recognize RC as a motivating force. The company's HSE policy/programme director acknowledged this saying: "We do that [on HSE], but we don't call it RC." One of the methods the company has chosen to reintroduce RC to all its operations is the use of CMA's Chemfacts, a multimedia training programme that addresses each of the codes.⁽⁵⁴⁾

Further evidence, from a non-industry source, of poor employee awareness or familiarity with RC comes from work by an American NGO, the public interest research groups (PIRGs). These groups have been monitoring the progress of Responsible Care since 1988 on the basis of the CMA's challenge (its unofficial motto) of: "Don't trust us, track us."

The PIRGs first survey of Responsible Care in 1992,⁽⁵⁵⁾ came up with results that the organization described as "disturbing". In February-March 1992, PIRG members called 192 CMA member facilities (that had reported the largest releases under the United States Toxics Release Inventory in the states chosen) in 28 states and asked nine basic questions. The survey found that:

• at 81 of the facilities -- 42 per cent -- callers could not reach anyone to answer their questions, despite repeated attempts;
• at 31 of the facilities -- 27 per cent -- the company contact either could not or would not answer any of the questions;
• at 61 facilities -- 55 per cent -- the company contact could only answer some of the questions, with 29 of these facilities answering less than half the questions;
• at 19 facilities -- 17 per cent -- the contact gave an answer to each of the nine questions and seemed to understand the spirit of Responsible Care.

In January 1998, the PIRGs issued a second report entitled "Trust us. Don't track us".⁽⁵⁶⁾ It, too, was based on a telephone survey in which PIRG staff and volunteers called 187 CMA member facilities in 25 states and asked seven basic questions. The results were again described as "disturbing":

• at 72 of the facilities -- 39 per cent of the sample -- callers could not reach anyone to answer their questions, despite repeated attempts;
• at 33 of the facilities surveyed -- 18 per cent -- the company contact either could not or would not answer any of the questions;
• at 40 of the facilities surveyed -- 21 per cent -- the company contact could only answer some of the questions; and
• at 42 of the facilities surveyed -- 22 per cent -- the contact gave an answer to each of the seven questions and seemed to understand the spirit of Responsible Care.

Over 75 per cent of the companies called did not provide answers to seven basic questions about chemicals used at their facilities.

In conclusion, the lower profile of RC at plant level owing to different use of terminology within the plants and in the outside world poses a dilemma for the industry in terms of recognition and understanding of the RC programme and its aims in terms of both employees and the general public. As one trade journal article on poor worker perception of RC notes: "Much of the problem is of the industry's making ... All too frequently, however, individual companies emphasize health, safety and environment programmes that broadly pursue the same aims but go under different names. Thus, company employees support the aims and goals of such corporate programmes while remaining blissfully ignorant of RC."⁽⁵⁷⁾ The article concludes:

If managers seriously want the concept of Responsible Care to be understood, let alone appreciated, by the general public, they must begin by using the term pervasively. They cannot expect people to sing the same song from the song sheet if they haven't been given the song sheet in the first place.⁽⁵⁸⁾

2.1.4. Worker involvement in RC

A problem closely linked to low employee recognition is that of criticism that input from workers' representatives into RC programmes is weak or non-existent. A 1997 report done for the ILO noted that serious problems persisted in the area of RC credibility and the involvement of non-management stakeholders: "In almost all of the [industry] programmes reviewed, input from workers' representatives was minor or completely absent."⁽⁵⁹⁾ The degree to which RC has stimulated more union-management cooperation on HSE remains unclear.

Despite continuing high-profile chemical industry support for the Responsible Care programme, a more recent survey by the International Federation of Chemical, Energy, Mining and General Workers' Unions (ICEM) indicates that workers and their trade union representatives are neither widely involved in nor well informed about the programme. The survey is entitled "Responsible Care: An ICEM survey of the understanding and participation of workers and their trade union representatives".⁽⁶⁰⁾ A total of 29 unions from 21 different countries responded to the ICEM questionnaire on Responsible Care, the main findings of which include:

• A total of 35 per cent of respondents were not even aware of the RC programme. This was not limited to unions in developing or newly restructuring countries.
• There was a clear bias towards the Japanese, Scandinavian and northern European unions amongst those who were both aware of the RC programme and in some way involved with it.
• The ability of workers and especially their union representatives in at least one highly developed country to get involved in a formal and meaningful way in the RC programme was considered extremely limited.
• Unions from the countries of Central and Eastern Europe and from developing countries are much less likely to be aware of the RC programme, let alone be involved in it.
• Of those unions aware of the RC programme -- including a number involved in one way or another, and who expressed an opinion -- there is considerable scepticism about its real value.

The ICEM General Secretary has expressed the view that RC is "everything to everyone at the moment".⁽⁶¹⁾ He argues that RC needs harmonization with common, measurable standards, and common training, plus a system of worker-owned inspectors to ensure accountability. He feels ICEM has a role in pushing what he terms "soft democracy". As governments retreat from responsibility, soft democracy is taking over. He cites the Global Forum on Chlorine Chemistry (see box 2.3) as an example of soft democracy, and a voluntary attempt by the chemical industry and trade unions to negotiate new standards on chlorine-containing products in the power vacuum created by the decline of government responsibility.⁽⁶²⁾
 

Box 2.3 The Global Forum on Chlorine Chemistry

The Global Forum on Chlorine Chemistry and Related Activities (the Forum) is a joint initiative by ICEM and the World Chlorine Council (WCC) which originated from discussions held in 1997. The Forum aims to pursue the possibility of conducting a sustainability study of a major chlorine-chemistry product line, joint health and safety scientific research, closer cooperation on the Responsible Care programme, and joint worker training especially in the developing world. Public interest groups are also participating in the Forum. Both labour and management have expressed the desire to define the long-term future of the global chlorine chemistry industries and the implications for workers employed within them.

Source: ICEM/WCC: Information note and statement regarding labour-management relations and the future of the chlorine chemistry industries (Brussels, 21 May 1998).

One consequence of lack of trade union involvement in RC is that it is generally not yet an item on trade union HSE training and education courses, even though trade unions normally have comprehensive HSE training and education programmes for general members, plant-level HSE representatives and HSE committee members. Nor is there systematically a trade union or worker voice in determining RC-related training activities, as is often the case for other kinds of training.

How could RC programmes be strengthened on the basis of active and meaningful trade union participation?⁽⁶³⁾ The broad outlines of such recommendations were framed by ICEM representatives at their 1998 world conference on HSE. Delegates called for a "Trade union-driven agenda on RC" based on developing a campaign for responsible production and use. Box 2.4 presents a statement of ICEM views on these questions.

ICEM has resolved to work jointly with the International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF), in respect of companies' voluntary standards in improving HSE standards on pesticide use, especially in respect of safety under conditions of use in developing countries.

In reply to such trade union concerns, the United Kingdom Chemical Industries Association (CIA) notes that many companies have extended their original plant safety committees to embrace health and environment issues as well. Some of these have been renamed RC committees and most of them include worker representatives.⁽⁶⁴⁾

Furthermore, the Japanese Responsible Care Council (JRCC) says that trade unions participate in RC activities at both the industry and enterprise levels. The president of the Japanese Federation of Chemical, Service and General Trade Unions (CSG RENGO), the national federation of chemical workers' unions, is a member of the JRCC advisory panel. At the enterprise level, trade union representatives participate in the HSE committees and are consulted on RC matters.⁽⁶⁵⁾

2.1.5. RC performance indicators

The industry perceives that it needs to develop performance indicators to measure progress in implementing the RC codes as part of company self-assessment and/or verification, and to be able to communicate its results to third parties. The development of performance indicators is being undertaken at various levels -- by national associations, and by bodies like CEFIC and ICCA.¨
 

Box 2.4 Voluntary industry initiatives versus industry agreements: A view from the ICEM

Part of the problem with the term "voluntary initiatives" -- a term which includes the high-profile chemical industry Responsible Care programme -- probably lies in a confusion of terminology. A clear distinction must be drawn between an industry voluntary "initiative" and an industry "agreement". Despite a number of views to the contrary, it may be perfectly consistent for an industry initiative to involve only industry (i.e. management) "stakeholders". The problem arises when an "initiative" is either promoted or perceived as an "agreement". From the perspective of the ICEM, an agreement -- unlike an initiative -- is something which has to involve at least two discrete groups of stakeholders, and implies a much higher level of commitment from the parties to it. Nor does an initiative become synonymous with an agreement simply through a process whereby industry co-opts onto "advisory boards" or "industry councils" a very limited number of individuals from other stakeholder groups. However desirable, such measures lie more in the realm of community outreach, public relations and general communication. At the same time, initiatives and agreements need not be mutually exclusive. Real commitments can and do stem from voluntary initiatives where such initiatives are underpinned by a series of agreements. This, in the view of the ICEM, is the direction in which the Responsible Care programme needs to develop. The Responsible Care programme should be recognized as what it really is -- a voluntary industry initiative involving a number of "codes" and working principles. It may be considered as a valuable industry sensitizing exercise and perhaps even as a necessary precursor to further commitment. However, whether the Responsible Care programme can in future be considered credible, and the extent to which it will really succeed, will depend on different criteria. One real measure of success as far as the ICEM is concerned will be the quality and number of agreements signed by Responsible Care companies as part of their commitment to the Responsible Care programme. Such agreements could in principle cover a wide range of issues including, but not necessarily restricted to, the priorities outlined in the six codes of the Responsible Care programme. Agreements, however, need to be reached between at least two parties, and a very good starting place would be to forge such agreements between Responsible Care companies and trade unions. The ICEM -- as the International Trade Secretariat covering the world's organized chemical workers -- has already indicated its willingness to help facilitate this approach. It would be a logical development of the Responsible Care programme; it would be in the interests of trade unions and their members as well as participating companies; it would help broaden the "ownership" of the Responsible Care approach; and it would add very considerable credibility to the programme and its participating companies. The ILO chemical sector meeting from 22-26 February 1999 will concentrate on one extremely important aspect of industrial policy, namely enterprise performance on health, safety and environment in the chemical industry. This meeting provides a good opportunity for both sides of industry to deepen their understanding of the relationships between voluntary initiatives and agreements and to explore ways in which the two can be mutually reinforcing. If this leads, as it should, to enhanced safety and environmental performance and a joint trade union/management approach and commitment to continuous improvement, it will have provided a very good forum for the development of credible voluntary initiatives and effective agreements.

Source: ICEM, July 1998.

CEFIC, for example, is developing a set of pan-European core parameters⁽⁶⁶⁾ on:

Safety and occupational health

(1) Number of fatalities

(2) Lost time injuries frequency rate

(3) Occupational illness frequency rate

Environmental protection

(4) Hazardous waste for disposal

(5) Non-hazardous waste for disposal

(6) Sulphur dioxide

(7) Nitrogen oxides

(8) Carbon dioxide and other global warming gases

(9) Volatile organic compounds

(10) Phosphorous compounds

(11) Nitrogen compounds

(12) Chemical oxygen demand

(13) Heavy metals

(14) Other substances that potentially impact human health or the environment

(15) Energy consumption and energy efficiency

Distribution

(16) Distribution incidents

This list is not complete. It is recognized that at least two areas need further development, namely product stewardship and the sector's consumption of resources.

The choice of parameters on which to collect data was dictated by the need to satisfy two key requirements:

(1) The desirability of incorporating HSE data which operating sites are actually collecting to comply with regulations, to help achieve performance/economic targets or to meet local needs. Therefore, in order to accommodate the current individual company needs and practices, these guidelines concentrate on a consistent set of parameters which will increase the effectiveness of reporting and ultimately result in a reduced reporting burden.

(2) The need to develop quantitative/qualitative information in relation to issues perceived as important by governmental bodies, legislators, politicians, the media, pressure groups and other influential bodies. Therefore these guidelines concentrate on reporting data in a transparent way and in a format that is easily understandable by the interested audiences.

Some national trade associations have published indicators relating directly to training and education. The Chemical Industry Federation of Finland (KT) publishes every year an indicator report giving information on about 30 indicators (lost-time accident figures, discharges to water, releases to air, waste, damages, use of natural resources, costs, etc.). Two of the indicators cover training and education, namely number of HSE courses in the companies and number of participants in these courses (see figure 2.1).⁽⁶⁷⁾

2.2. Responsible Distribution/Care

Through the International Council of Chemical Trade Associations (ICCTA), chemical distributors and traders are promoting their own voluntary initiative which goes beyond the requirements of HSE in that it demands continual improvement. It is called Responsible Care/Responsible Distribution, since the American programme is a Responsible Distribution process and for legal reasons of enforcement and control that difference has to be catered for. The chemical traders and distributors of some 22 countries are now actively involved in their international programme that enables chemical traders and distributors to develop their Responsible Care/Responsible Distribution programme. The term "Responsible Care" may only be used where there is an agreed effective partnership with the manufacturing association in the country concerned. In the United States and four European countries (Belgium, France, Italy and Portugal) there is no such partnership despite the fact that the programmes are compatible. In the United States there is a signed accord of understanding between the manufacturers and the distribution associations. Therefore, in these countries and in Canada, the programme is called Responsible Distribution. In other European countries, there are three groups of distributors:

• distributors participating in the RC programmes of the national chemical industry associations (e.g. Spain);
• distributors participating in an RC programme on the basis of an agreement between their national chemical distribution and trade association and the respective national chemical manufacturing association (e.g. Germany, the Netherlands and the United Kingdom);
• distributors participating on the basis of a partnership agreement with CEFIC (e.g. Australia and the Scandinavian countries).

Whatever the name chosen, however, the distributor initiatives are designed to be complementary and supportive of the chemical industry's Responsible Care programme. As an article in Careline magazine notes, the link between chemical manufacturing and distribution is critical in terms of product stewardship, and often publicly visible if an accident occurs. It is also a complex relationship. Not all chemical distributors own their own delivery trucks and warehouses. In the United Kingdom, for example, 70 per cent of chemical distribution is contracted out to road hauliers. Typically, up to 20 per cent of European chemical manufacturers' sales are made through distributors.⁽⁶⁸⁾

2.2.1. Structure of Responsible Distribution

ICCTA's programme has eight guiding principles, one of which concerns training. Companies are committed to ensuring that all employees are aware of their company's commitment to provide the training necessary that will enable them to contribute to the achievement of HSE objectives. These principles are:

• legal requirements;
• management of risk;
• policies and documentation;
• provision of information;
• training;
• emergency response;
• ongoing improvements;
• community interaction.

The guiding principles contain within them product stewardship throughout the distributive process, are supported by codes of conduct, and examined by a self-assessment questionnaire. Only when this questionnaire and the three-year improvement plan have been completed, and the coordinator has attended training sessions and supplied the company's indices of performance data, can the logo be used. Even then, the distributor association retains control and is prepared to take it away again if the company does not honour its commitments. In Europe, the ICCTA generic programme is actively being put into place by the associations in membership of the reformed and revitalized European Association of Chemical Distributors (FECC) which aims to bring the Responsible Care/Responsible Distribution programme of chemical traders and distributors up to the same speed in each country. As the Association's new Director has indicated a vital part of the FECC is its commitment to the ICCTA generic document for Responsible Care/Responsible Distribution. This, it is hoped, will help to demonstrate that FECC members are fully committed to continual improvement in health, safety and environmental issues and fully committed to the principles of Responsible Care and product stewardship. The fundamental idea is that top line management commits itself to the programme and takes all necessary decisions pertaining to it. The associations are in close cooperation with the manufacturing associations in their countries and the FECC is in close cooperation with CEFIC.

FECC's member associations are developing their own training and education programmes. The British Chemical Distributors' and Traders' Association (BCDTA) trains personnel in some 130 companies who are full association members. The following three types of training, specifically entitled RC Training Workshops, are given:

(1) back-to-basics training package -- for new companies and new coordinators;

(2) training for companies on auditing warehouses and hauliers;

(3) training in emergency response.

This training programme is supported by local area committees which regularly meet to explore problems and help to develop the programme.

Because of the low training cost of about £80 per person, more enlightened companies bring a large number of their staff to the workshops, so that the effect of the training will trickle down.⁽⁶⁹⁾ To implement its community interaction (COP), which is a difficult guiding principle because most members are not area-oriented, the BCDTA has linked up with the British Groundwork Trust to develop an educational package for children on chemical distribution, based on a theatre group performance.⁽⁷⁰⁾

In the United States, the National Association of Chemical Distributors (NACD)⁽⁷¹⁾ has over 300 member companies, located in all regions of the country, operating 1,000 chemical distribution locations and serving some 750,000 customers. The Association also has member companies in Canada and Europe. Approximately US$18 billion worth of American chemical industry sales are made through chemical distributors. Member companies are largely entrepreneurial and generally service a particular geographical region and a specific industrial sector. They are typically small businesses, although some companies are national in scope. All member companies are committed to product stewardship and responsible distribution in every phase of chemical storage, handling, transportation and disposal. A condition of membership of the Association is a signed commitment to the NACD Responsible Distribution Process (RDP), which requires members to continuously improve performance in protecting HSE and to file periodic self-assessments. Another member-voted condition of membership is mail-in third-party verification of company policies and procedures with Underwriters Laboratories Inc. as the third-party verification firm. NACD has terminated membership of member companies for not complying with RDP requirements. The Association has set up a Chemical Education Foundation (CEF) to establish a chemical product stewardship network as a primary national resource for conducting research and educational programmes for proper distribution practices and the safe handling, use, storage, transportation, disposal and recycling of chemical products. The CEF produces training materials and resources which can help its members to implement the product stewardship and community outreach codes of RDP. It is considered a valuable resource for members, the community, chemical manufacturers and others. With regard to training and education of the Associations's members, the RDP code coordinators are required to attend at least one code coordinator workshop within a year of joining NACD. Thereafter, they are encouraged to attend one of the three workshops held across the country in order to keep abreast of recent developments in RDP. The Association has developed several training and implementation resources for its members to use, including an implementation questionnaire and software, an implementation workbook, an implementation guide -- all of which help them write and update their RDP policies and procedures.

2.2.2. Performance indicators

In Europe, whilst FECC members have self-assessment questionnaires and indices of performance, they are also looking ahead to a potential third-party assessment document -- European Single Assessment Document (ESAD) -- which will be based on 200 audit questions. For chemical distributors, a single assessment audit could be of major benefit as it aims to replace multiple audits by different suppliers; no company enjoys being on the receiving end of a procession of auditors asking more or less the same questions. Another advantage of basing the assessment or audit on the ICCTA programme is that the latter is widely used around the world. Development of ESAD is now at a decisive stage. In the second half of 1998, test audits will be carried out in France, Germany and the United Kingdom. Simultaneously, legal aspects of the document will be assessed by FECC lawyers, and third-party auditors will be trained in the handling of the questionnaire. In early 1999, FECC intends to hold an information day for all interested parties.⁽⁷²⁾

2.3. Coatings Care

The paint and printing ink manufacturing industries have launched their own international, voluntary HSE programme, dubbed Coatings Care (CC). It is a programme describing good management practices with the objective of improving the performance of the coatings industry in the fields of the environment, safety, health, distribution and product stewardship. The CC programme was originally developed in 1996 by the American National Paints and Coating Association (NPCA). It has been approved by the International Paint and Printing Inks Council (IPPIC),⁽⁷³⁾ and has also been endorsed by the European Council of the Paint, Printing Inks and Artists' Colours Industry (CEPE).

2.3.1. Relation to Responsible Care

Coatings Care is designed to be complementary to and supportive of the chemical industry's Responsible Care programme and was established with similar objectives. Like RC, the basic principle is one of continuous improvement. Any company complying with Responsible Care is considered to be also fulfilling the requirements of Coatings Care. It also integrates HSE practices that are consistent with other industry standards such as those found in the ISO 14000 series on environmental management and EMAS. However, Coatings Care has its own logo, which is distinct from the Responsible Care logo and may be used by participating companies as part of their corporate stationery and their internal and external communications. The rationale for a different logo and identity is based on two main factors. First, as the Chairman of CEPE's HSE operating group says:

Fundamental differences [vis-à-vis the chemical industry] all add up to a different set of challenges for coatings operations. Compared with the chemicals sector, coatings operations are generally of lower average size, are less involved in chemical processes, supply more products directly to the public and supply a wider product range. These differences make it logical for the [coatings industry] to place more emphasis on product stewardship issues as against chemical process safety and site emergency response, compared to the priorities of big chemical sites.⁽⁷⁴⁾

Secondly, public perception also played a part in the sector's decision to opt for its own programme. As a CEPE spokesperson pointed out: "While the chemicals industry is still saddled with a very negative image, the public associates positive images such as protection and colour with paints and coatings."⁽⁷⁵⁾

Misgivings have occasionally been expressed about the separate approach that CC represents. For example in 1996, the then Chairperson of ICCA's Responsible Care leadership group said that: "I am concerned that if there are too many logos on the street, then the public's mind will be confused and that will not help."⁽⁷⁶⁾

Coatings Care is generally seen by its creators as supportive of, and not in conflict with, RC. The Director of HSE Affairs of the National Paints and Coating Association (NPCA) in the United States said that there was no controversy over RC with the chemical industry and the CMA and that CMA acknowledged the fact that CC was complementary to and supportive of RC goals and wait a long way towards carrying RC ethics downstream.⁽⁷⁷⁾

CEPE, the NPCA's counterpart in Europe, also sees CC and RC as compatible and is actively seeking cooperative understandings with its colleagues in the chemical associations. In Europe, there are some 1,400 companies and national organizations in 16 countries. According to CEPE, the majority of these national associations are adopting HSE codes of management practice. Implementation will take place either under the umbrella of RC or CC. Austria, Belgium, Germany, Italy and Spain are linked to the RC programme. France, the Netherlands and the United Kingdom are promoting the CC initiative. Other countries, such as those in the Nordic region, are planning to adopt CC.⁽⁷⁸⁾

In Europe, CC is viewed by many national associations not as a new subject but as an extension of existing HSE management programmes. The Netherlands Association, for example, sees CC as an extension of an HSE management programme that was launched in 1989, focusing mainly on process control. Several other associations in Europe have already developed HSE- Care systems and can integrate CC with what is already in place.⁽⁷⁹⁾

In Japan, four leading paint makers were originally at the forefront of RC activities in the coatings industry. However, in 1996, because of difficulties with RC implementation, both the Japan Paint Manufacturers' Association (JMPA) and the Japan Printing Ink Manufacturers' Association switched to the CC programme. The JMPA has declared that it will establish "a level of consistency" between CC, RC and ISO 14000, and study aspects of manufacturing, transportation and distribution, product stewardship and community responsibility.⁽⁸⁰⁾

2.3.2. Structure of Coatings Care

National associations adopting Coatings Care encourage their members to participate and may implement the programme on a voluntary or mandatory basis. Successful implementation of Coatings Care is seen to require not only employee participation but also the unambiguous commitment of top management to carry out the management practices identified.

The four coatings care codes of management practice (CEPE's version was published in June 1996) have been specifically designed for the needs of the coatings industry. In particular, some flexibility is included in the codes to reflect the diversity of the industry's products and practices. For each code, CEPE member associations adopting the Coatings Care programme will have to develop a self-evaluation checklist to assist participants in implementing the management practices. Such a checklist may be used to assess current operations or identify areas for future action.

Coatings Care policy statement

All national Coatings Care programmes are based on the following policy statement agreed at IPPIC:

Participating associations will support, develop and communicate a Coatings Care programme that may be utilized by member companies to protect worker and community health and safety as well as the environment. Such a programme shall:

• promote efforts to protect employees, customers, the public and the environment;
• provide relevant information on the safe use and disposal of industry products to customers and make such information available to the public on request;
• make protection of health, safety and the environment an early and integral part of the organizational planning process;
• comply with all legal requirements which affect operations and products;
• be responsive to community concerns;
• assist governments in the development of equitable and attainable standards.

Codes of management practice

Manufacturing code: It seeks to ensure that plant operations are consistent with established health, safety and environmental practices; it reflects regulatory and legislative requirements as well as industry trade practices; it integrates practical and flexible considerations to reflect the diversity of the coatings industry. It covers the areas of:

• occupational safety and health;
• operations (process safety);
• environmental management (pollution prevention/waste management).

Transportation and distribution code: It seeks to ensure the safe shipping of coatings products to the industry's customers and to reinforce the integral role of health, safety and environmental considerations in the distribution chain. It covers the areas of:

• training;
• risk management;
• carrier performance;
• distributors;
• emergency response.

Product stewardship code: It seeks to establish health, safety and environmental considerations as an early and integral part of product formulation and to communicate appropriate safeguards for product use and disposal to customers. Product stewardship must be viewed as a shared responsibility and therefore understood by all those responsible for product formulation, manufacturing, marketing and customer support. Product stewardship principles apply for all classes of industry products. The code applies to the following areas:

• product development;
• health, safety and environmental education and information;
• product safety (product use).

Community responsibility code: It has two major elements; the first seeks to help protect employees and communities by ensuring that each coatings facility has an established programme coordinated with local authorities to respond to emergencies; the second is to assist CEPE and its participating associations in establishing and maintaining good communications with the community on questions and concerns regarding health, safety and the environment. It covers the following areas:

• emergency response;
• employee education and training;
• community liaison.

Evaluation and improvement

For each area of responsibility, Coatings Care defines specific management practices that address appropriate health, safety and environmental considerations for coatings manufacturers. In addition to defining these management practices, Coatings Care allows for the establishment of systems for continuous self-evaluation, implementation and improvement to guide the efforts of individual companies.

To stimulate HSE training, the British Coatings Federation (BCF), for example, has produced a training package about Coatings Care. It consists of a series of manuals and overheads (transparencies) designed for general awareness-raising for management and workers, covering production, technical aspects, sales and marketing, and including material for training the trainers. It outlines the essential elements and benefits of the CC initiative, identifies "What to do" and "How I will be affected" for the different groups, and discusses the different codes in detail.

2.4. The pesticide industry's Global Safe Use Initiative

The Global Crop Protection Federation's (GCPF)⁽⁸¹⁾ Global Safe Use Initiative involves hundreds of separate projects, both in developed and developing countries. A key element of this wider initiative is the three safe use pilot projects, launched by the GCPF in 1991 with the support of its major international member companies to provide voluntary training and education for all users and handlers of crop protection products (the industry term for agricultural pesticides) in Guatemala, Kenya and Thailand. The idea of the pilot projects was conceived in the light of the importance that the pesticide industry put on the FAO Code of Conduct for the Distribution and Use of Pesticides.⁽⁸²⁾ The projects operate in a transparent and open fashion, involving local people, particularly farmers.

All three projects seek to:

• educate and train farmers, retailers, doctors and schoolchildren;
• protect people and the environment;
• prevent and treat personal contamination;
• recycle and/or dispose of empty containers safely;
• enforce regulatory legislation;
• create local expert poison centres.

Each project consists of three distinct phases: (i) Phase 1 -- Implementation, 1991-1994; Phase 2 -- Extension, 1995-97; and Phase 3 -- Sustainability, 1998-2000.

2.4.1. Summary of results

Guatemala

In Phase 1, a baseline survey revealed particular local weaknesses at farmer and retailer level. Project training targeted workers throughout the distribution chain, as well as farmers and users. Dissemination of advice and information materials on personal protection and on the disposal of waste and empty containers was a priority. In order to create a multiplier effect in which the trainees become trainers, the starting point was to train 800 government extension workers on the safe distribution and use of agricultural pesticides, with a special focus on the rational management of pests.

In Phase 2, while training and education remained the core activities, the focus turned to small vegetable growers. A more personal approach was adopted, with field visits and demonstration plots a prominent feature. One master trainer now resides in each target community to coordinate the efforts of extension workers, agricultural guides, home educators and teachers.⁽⁸³⁾

Kenya

In Phase 1, training concentrated on safe handling and use. The project team developed a mass training system which allowed large groups of 150-250 farmers to be trained at the same time. Each training event involved around 25 trainers. The trainees were split into small groups and gradually worked their way around a circuit of information stations to cover specific topics.

Persuading farmers to use protective clothing was one of the biggest challenges. They tend to see it as uncomfortable and expensive. Locally designed and manufactured clothing is addressing these problems. Another difficulty was that women in Africa have a cultural aversion to being seen in trousers. Kenyan women were therefore asked to design their own protective clothing, and the results have been widely publicized.

In Phase 2, more farmers and retailers have been trained. There was a strong demand from horticultural exporters for training/retraining because the safe use project is seen as the best way to satisfy customers that good agricultural practices are being followed.⁽⁸⁴⁾

Thailand

In Phase 1, the safe use project sought to raise industry standards. Training modules were developed and tested for retailers, medical personnel and farmers. An award, accreditation, advice scheme was used to provide a checklist of minimum requirements relating to plant location, storage, packing and labelling, employee safety, transport and disposal.

Farmer training was a collaborative venture, building on existing Thai Pesticide Association training programmes. Training materials, including audio-visuals and safety handbooks, were upgraded.

Personal protection has been a major feature of the project. By demonstrating to farmers the principles of good protective clothing and encouraging them to develop their own personal protective equipment, good progress has been made.

Workers in the country's citrus fruit plantations have been identified as a priority target group and measures aimed specifically at reducing exposure in citrus groves have been promoted through the model farm concept. They include the use of improved application equipment, residue monitoring and additional training in good agricultural practice.

All the programmes established in Phase 1 were continued in Phase 2 (extension), with further training of the same groups.⁽⁸⁵⁾

2.4.2. Future developments

The GCPF states that the safe use pilot projects in Guatemala, Kenya and Thailand have "made a real and sustained contribution to the safe and responsible use of crop protection products. They have proved that human behaviour can be changed, but that to do so requires detailed and continuous training and education programmes".⁽⁸⁶⁾ Through the GCPF, global companies have invested US$10 million to support the first two phases of the pilot projects while local associations and individual companies have made significant "in kind" contributions.

In Africa, safe use pilot projects are beginning to spread to other countries, albeit at a slower rate than in Asia or Latin America. This is a direct consequence of the lack of local funding and the generally less well developed national trade associations in Africa. In the United Republic of Tanzania, however, a safe use project is ahead of schedule, with educational material now available and a first radio series completed. Some 240 extension staff and 50,000 coffee farmers have been trained.

In Asia, efforts to extend these pilot projects to other countries in the region met with a mixed response.

In Latin America, safe use programmes organized by national associations through cash and "in kind" contributions from a variety of sources including aid donors, governments and GCPF are now operating in Argentina, Brazil, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, El Salvador, Honduras, Mexico, Nicaragua, Panama and Venezuela.

2.4.3. A trade union perspective

The International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF)⁽⁸⁷⁾ up to now has not been directly involved with the safe use initiative. However, whilst recognizing the "value added" potential that voluntary initiatives may bring to HSE standards, the IUF is concerned at the lack of independent monitoring of the safe use initiative and its achievements and limitations in improving pesticide user HSE performance. It is concerned that in many cases, safe use training may be carried out solely by the pesticide sales force rather than in cooperation with independent and suitably qualified trainers. Furthermore, the IUF emphasizes that a general industry "training" talk/address for one or two hours or more to a village audience of farmers and farm workers is not the same as small group, structured and teacher-led training courses.

The IUF also highlights the need for links between structured training and education courses and practical schemes to ensure that the benefits of that training can be put into effect by the course participants. Use of personal protective equipment (PPE), for example, is usually a key part of pesticide operator HSE training. A problem is that many small farmers or farm workers cannot afford PPE clothing and equipment, so that the training recommendations cannot be put into effect and, despite the training, there may be no practical, on-the-ground improvement in personal levels of spray operator protection. IUF believes that as part of the Global Safe Use Initiative, pesticide companies should develop more responsible marketing strategies to ensure basic but high HSE standards worldwide and ensure independent verification of those standards. To this effect, IUF seeks cooperation with other trade union organizations and pesticide manufacturers to help ensure that the ideals and performance standards of the international pesticide industry's safe use initiative are being met in practice.⁽⁸⁸⁾

Notes

1.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 3.

2.  ICCA: Responsible Care status report (Brussels, 1996), p. 4.

3.  The International Council of Chemical Associations (ICCA) is a council of leading trade associations representing chemical manufacturers worldwide. The purpose of the ICCA is to exchange views among members, to coordinate action by council members, and to present an international chemical industry view to organizations. Established in 1989, it has a peripatetic secretariat moving from federation to federation on a biennial basis. Its Responsible Care Leadership Group (RCLG) was established in 1991.

4.  ICCA: Position paper on sustainable development and the chemical industry (Arlington, United Staidest6), p. 3.

5.  Dan Roczniak: Responsible Care, Proceedings of the OECD Workshop on Non-Regulatory Initiatives for Chemical Risk Management. OECD Environmental Health and Safety Publications, Series on Risk Management No. 7 (Paris, 1997), pp. 13-20.

6.  ICCA: Responsible Care and ICCA contributions to ISG-3 themes (Geneva, IFCS Secretariat, 1998), p. 4.

7.  CEFIC: Responsible Care 1996 (Brussels, 1996).

8.  ICCA: Responsible Care status report (Brussels, 1996), Executive Summary.

9.  CEFIC, the European Chemical Industry Council, is a Brussels-based organization representing national chemical federations and chemical companies of Europe. CEFIC represents, directly or indirectly, more than 40,000 large, medium and small chemical companies in Europe, which employ about 2 million people and account for more than 30 per cent of world chemicals production.

10.  Kevin Munn: Responsible Care and related voluntary initiatives to improve enterprise performance on health, safety and environment in the chemical industry, Sectoral Activities Programme Working Paper No. 109 (Geneva, ILO, 1997), available in English only.

11.  "Canadian producers prepare for round two", in Chemical Week (London, 2-9 July 1997), p. 72.

12.  "Responsible Care -- A revolution hits the 10-year mark", in Chemical Week (Washington, DC, 1-8 July 1998), p. 37.

13.  "Canada revs up the program", in Chemical Week (Washington, DC, 1-8 July 1998), p. 105.

14.  "Responsible Care -- A revolution hits the 10-year mark", op. cit., p. 37.

15.  CMA: Responsible Care progress report 1997 (Arlington, United States, 1998), p. ii.

16.  "Distribution delay?", in Chemical Week (Washington, DC, 1-8 July 1998), p. 76.

17.  "CEFIC applies pressure at company level", in Chemical Week (Washington, DC, 2-9 July 1997), p. 79.

18.  Ryszard cigala and Andrzej Kreslak, Polish Chamber of Chemical Industry's Ecological Task Force: "The chemical industry in Poland: A brief review" (Warsaw, May 1998).

19.  PACIA: Responsible Care report 1997 (Melbourne, 1997), p. 1.

20.  Personal communication dated 24 June 1998 from Jim Smith, RC Coordinator, PACIA, Australia.

21.  "New way to comply in Australia", in Chemical Week (London, 2-9 July 1997), p. 86.

22.  Daniel Wu: The development of Responsible Care in Taiwan (Taiwan, Asia Pacific Responsible Care Conference, 1998).

23.  ibid.

24.  ILO: Responsible Care in India: A status report (Geneva, 1998).

25.  "Bhopal's legacy", in Chemical Week (Washington, DC, 2-9 July 1997), p. 84.

26.  Personal communication dated 18 June 1998 from Liz Anderson, RC Manager, CAIA, South Africa.

27.  ICCA: Responsible Care status report (Brussels, 1996).

28.   "ICCA pursues unified global expansion of Responsible Care", in Careline, Issue No. 11 (London, Apr.-June 1998), p. 3.

29.  Agenda 21 is the action programme of the United Nations Conference on Environment and Development (UNCED), the Earth Summit, held in Rio de Janeiro, Brazil in 1992. It is described as a blueprint for action for global sustainable development into the twenty-first century. It consists of 40 chapters on all the issues concerned with sustainable development and environment, plus a Rio Declaration and guiding principles.

30.  "Responsible Care set for UN General Assembly", in Careline, Issue No. 3 (London, Mar. 1996), back page.

31.  CMA: "Responsible Care goes to the UN", in Responsible Care News (Arlington, United States, Oct. 1997), p. 7.

32.  Personal memorandum dated 30 June 1997 from Dan Roczniak, RC Coordinator, CMA, Arlington, United States.

33.  ICCA: Responsible Care status report (Brussels, 1996), p. 13.

34.  "Globalization will hamper sustainability, say trade unions", in Careline, Issue No. 11 (London, Apr.-June 1998).

35.  Telephone interview on 7 May 1998 with Mike Moss, ICI HSE Group Systems Development Manager.

36.  ibid.

37.  Florian Wegleitner: Responsible Care -- ein Vergleich -- der Initiative für Gesundheit, Sicherheit und Umweltschutz in der chemischen Industrie -- zwischen Osterreich und England (Vienna, Austrian Chemical Industry Association, 1997), available in German only.

38.  Personal interview on 16 Apr. 1998 with Mr. Stuart Aaron, RC Coordinator, Chemical Industries Association, United Kingdom.

39.  "Europe begins to measure performance", in Chemical Week (London, 1-8 July 1998), p. 112.

40.  "RC logo out of favour", in European Chemical News (Brussels, 25 Nov.-1 Dec. 1996), p. 20.

41.  "Making Responsible Care an obligation in Brazil", in Chemical Week (London, 1-8 July 1998), p. 109.

42.  Emma Chynoweth: "Is Europe stalling?", in Environment Review presented with European Chemical News, July 1997, pp. 32-34.

43.  Personal interview on 16 Apr. 1998 with Geoff Chalfont, Chris Beckett et al., BP Chemicals, London.

44.  Personal communication dated 18 June 1998 from Liz Anderson, RC Manager, CAIA, South Africa.

45.  DuPont Canada: Responsible Care compliance verification report, undated.

46.  Monsanto Canada: Responsible Care compliance verification report, undated.

47.  Extracts from Canadian companies RC compliance verification reports as provided by the CCPA (Ottawa, various dates).

48.  Rhône-Poulenc Canada: Responsible Care compliance verification report, Nov. 1994.

49.  Emma Chynoweth: "Is Europe stalling?", in Environment Review presented with European Chemical News, July 1997, pp. 32-34.

50.  "Progress slows in push to involve employees -- Unions take a closer look, in Chemical Week (Washington, DC, 2-9 July 1997), pp. 64-65.

51.  CMA: Responsible Care: Adding value to your company (Arlington, United States, 1997), p. 15.

52.  ibid.

53.  "Progress slows in push to involve employees", op. cit., pp. 64-65.

54.  "Getting organized", in Chemical Week (Washington, DC, 1-8 July 1998), p. 97.

55.  Public Interest Research Groups: Trust us. Don't track us: An investigation of the chemical industry's Responsible Care program (Washington, DC, Mar. 1992).

56.  op. cit., Jan. 1998.

57.  "One key to Responsible Care -- Better work with labor, in Chemical & Engineering News, Jan. 1998, p. 17.

58.  ibid.

59.  Kevin Munn: Responsible Care and related voluntary initiatives to improve enterprise performance on health, safety and environment in the chemical industry, Sectoral Activities Programme Working Paper No. 109, Geneva, 1997.

60.  ICEM: Responsible Care -- An ICEM survey of the understanding and participation of workers and their trade union representatives (Brussels, 1998).

61.  Comments on 7 May 1998 by Vic Thorpe, ICEM General Secretary to the ICEM World Health, Safety and Environment Conference, Geneva, 5-7 May 1998.

62.  ibid.

63.  Personal interview on 6 May 1998 with Reg Green, ICEM HSE Officer at the ICEM World HSE Conference, Geneva, 1998.

64.  Personal communication from Stuart Aaron, RC Manager, CIA, London, July 1998.

65.  Personal communication dated 21 July 1998 from Motoo Kawamata, Deputy General Manager, JRCC, Tokyo, Japan, and Yasunori Kakinuma, Director of Policy Planning Office, CSG Rengo, Tokyo, Japan.

66.  CEFIC: HSE parameters reporting (Brussels, 14 July 1998).

67.  Personal communication dated 20 July 1998 from Mr. Aimo Kastinen, Director, KT, Helsinki, Finland.

68.  "Single assessment document for distributors", in Careline, Issue No. 11 (London, Apr.-June 1998).

69.  Personal interview on 16 Apr. 1998 with Mr. John Parkinson, BCDTA, London., United Kingdom.

70.  ibid.

71.  Personal communication dated 21 July 1998 from Camille Soriano, National Association of Chemical Distributors, Arlington, United States.

72.  Personal communication of 8 July 1998 from Dr. Hans Out, Director-General, FECC, Brussels, Belgium.

73.  The International Paint and Printing Inks Council (IPPIC) is made up of the national associations of Australia, Canada, Europe, Japan, Mexico and the United States. It has no fixed secretariat.

74.  "Gearing up to climb the Coatings Care mountain", in Careline, Issue No. 5 (London, Oct. 1996), pp. 6-7.

75.  Telephone interview on 15 Apr. 1998 with Wayne Smith, British Coatings Federation, Leatherhead, United Kingdom.

76.  Debbie Jackson: "Coatings brush up on product stewardship", in European Chemical News (Brussels, 14-20 Oct. 1996), pp. 18-20.

77.  ibid.

78.  Richard Kok: Development of SHE Care in the European coatings industry (Brussels, CEPE, undated), speech made to NCPA meeting.

79.  ibid.

80.  "Gearing up to climb the Coatings Care mountain", in Careline, Issue No. 5 (London, Oct. 1996), pp. 6-7.

81.  The Global Crop Protection Federation (GCPF) operates through a network of six regional associations representing Africa/Middle East, Asia-Pacific, Europe, Latin America, North America and Japan. These regional associations in turn encompass the national associations in their geographical areas. In total, the pesticide industry has more than 70 national trade associations and their voice is ultimately represented through GCPF.

82.  GCPF: "Safe use pilot projects in Guatemala, Kenya and Thailand" (Brussels, 1998).

83.  ibid.

84.  ibid.

85.  ibid.

86.  ibid.

87.  The International Union of Food and Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF) is a worldwide federation of trade unions representing workers employed in agriculture and plantations, the preparation and manufacture of food and beverages, hotels, restaurants and catering services, and all stages of tobacco processing. The IUF secretariat is in Geneva, Switzerland.

88.  Personal interview on 10 July 1998 with Ron Oswald, General Secretary, IUF, Geneva, Switzerland.

3. Voluntary initiatives and HSE training and education

Training and education are part of the same continuum. Both lead to the development of competence, i.e. knowledge, skills and attitudes. Both lead to a variety of outcomes, some of which lend themselves to economic analysis. For training, however, the emphasis is on the application of skills to practical use; for education, the emphasis is on knowledge and understanding. General education leads to literacy, numeracy and general knowledge about a wide range of subjects. Vocational and technical training involve the development of knowledge, skills and attitudes required to carry out a particular economic activity, such as a job or occupation; such competence can be viewed as a factor of production, i.e. as human capital, a fact that is particularly clear in the case of industrial skill training, which is directly linked to employment. Training tends to refer to shorter-term programmes organized and taught by companies, trade unions, academic and non-academic institutions, while education refers to longer-term programmes of formal study at accredited institutions.

The term "training and education" in respect of VIs is understood in a broad sense in this report. In particular, "awareness raising", aimed both at those working in the industry and at third parties and the general public, is included.

The last ILO review of general training issues in the chemical industries showed that training needs were changing as plants become more sophisticated and automated, resulting in changes in work organization and more shift work to allow equipment to be operated continuously or for long periods. These technology-driven changes also tended to mean fewer jobs for unskilled or less skilled workers, while higher training was being demanded for technicians and plant operatives. More tasks were being contracted out, leading to concerns about the training required for the staff of the external firms performing such tasks. Training was becoming more of a main-line activity, with a systematic review of individual training needs related to company needs and objectives. Increasingly, line managers would have to assess the competence of existing employees and plan training programmes for their professional development. Routine review of the effectiveness of training would become more common, and linkages of company training targets to relevant national or international standards would become the norm.⁽¹⁾ Future training for the chemical industries was expected to be targeted towards flexible, multiskilled workforces. An increasing demand was foreseen for all types of management and team leadership training. Interpersonal skills would acquire greater importance, as would the ability to assimilate new "how to learn" techniques. Basic training in transferable skills and flexibility would become of paramount importance.⁽²⁾ The development of personal characteristics -- for example, the ability to work as a member of an interdisciplinary team, to communicate effectively and to learn -- would be at least as important as competency in knowledge and skills. Management training, training in HSE and the development of a transferable system would also be important.

Regarding the specific training needs related to environmental and social expectations, the consensus of the last (1995) ILO meeting for the chemical industries was as follows:

Pressure for improved environmental skills has been an important feature of the 1990s for the chemical industries. There is clearly a need for a better understanding by the public of ecological matters based on scientific grounds. The period has seen the development and application of the Responsible Care concept, an employers' initiative now adopted in many countries, with its underlying theme of training for all staff in environmental protection topics. In view of rising expectations, there is a need for better links with schools, in order to explain the industries' position and philosophy. The implications for training are numerous: (i) good sound basic training is essential; (ii) job training should be of a high standard, preferably leading to recognition of qualification; (iii) attention should be given to the training of drivers; (iv) correct procedures, including emergency procedures, should be written down, fully understood, and followed; (v) company environmental policy, in relation to statutory or voluntary obligations, should also be written down and understood by all staff; (vi) staff need to be trained and assisted in how to address external audiences; (vii) safety and health and environmental issues should form part of all training programmes.⁽³⁾

3.1. The impact of VIs on HSE training and education

A key question addressed by this report is: what impacts have voluntary initiatives had on HSE training and education at the levels of:

• manufacturing companies/corporations -- both large and small, and including contractor training;
• trade associations, including those in developing countries;
• distributors and suppliers (based on a product life cycle approach);
• the wider public, including decision-makers and communities affected by chemical industry operations?

In the light of the performance improvements sought by VIs, have HSE training and education systems, programmes and standards had to be upgraded, or radically modified in the light of VIs? If so, in which ways, at which levels, and affecting which groups, and numbers of people?

A further key question is: what will the future trends and needs be in VI HSE training and education, within the context of broader changes in the chemical industry as a whole?

In respect of HSE training and education, VIs have brought about important changes. First, they have placed a new emphasis on environmental training and education, often complementing existing occupational health and safety training at plant/company level. This environmental education and training when applied to employees, managers and workplaces encompasses education for general awareness of environmental concerns; education and training toward modifying work practices, processes and materials to reduce the environmental impact of industrial processes on local communities; professional education for engineers and others seeking expertise and careers in environmental fields; education and training of workers in the growing field of environmental abatement, including hazardous waste clean-up, emergency response to spills, releases and other accidents, and asbestos and lead paint remediation.⁽⁴⁾

With the environmental element growing in importance, there has also been a need to better integrate occupational health and safety with environmental training. There is evidence that VIs may help such integration. One of the conclusions, for example, of a comparative study by the Austrian Chemical Industry Association (FCIO)⁽⁵⁾ of RC implementation in Austria and the United Kingdom was that RC had strengthened integration of these three elements in management systems in the two countries.

Secondly, VIs have meant that companies and trade associations have had to be more outward looking, prepared for dialogue and interaction with non-industry groups, and to extend their awareness, training and education activities beyond the factory gate. This has meant new types of training and education with, for example, customers and suppliers. It has also meant developing training and education activities for new audiences or target groups, such as local communities around chemical sites. These new activities might not be HSE-focused training as such but, rather, awareness raising both within a company and outside it. They are also likely to place an emphasis on behavioural change training, given that VIs are often as much, if not more, about changing attitudes than providing specific technical skills training.

The following sections present some examples of VI-associated HSE training activities being carried out at the various levels identified at the beginning of this section, viz. manufacturing enterprises, trade associations, suppliers and distributors and the wider public.

3.2. Company and plant-level training and education, including SMEs

In many companies, HSE training and education programmes for various categories of staff existed before industry-initiated VIs, environmental agreements and environmental management systems and standards were developed. The distinct impact of these new voluntary initiatives on company/corporate HSE training and education -- the difference they have made for HSE training -- is often difficult to isolate for a variety of reasons.

Firstly, at the plant level, external initiatives -- Responsible Care, EMAS, ISO standards, etc. -- are often merged into the existing corporate HSE management systems, programmes and activities. As such it becomes difficult, if not impossible, to identify the particular impact of any given initiative. Rather general trends in improvement in corporate HSE performance have to be looked at. CEFIC guidance on RC, for example, acknowledges this problem:

While success for Responsible Care depends on the highest level of management commitment, it also calls for support from every employee, in all activities of a company, from research to manufacture, sales or distribution. Employees so committed are ambassadors for the industry in the community at large. Employee involvement will be best served if the Responsible Care message is presented within the framework of existing health, safety and environmental initiatives (emphasis added). To help in the development of such a "culture" the national associations progressively develop training programmes, videos and other aids to win the understanding and support of employees.⁽⁶⁾

Secondly, performance indicators which would allow measurement of the impacts of new initiatives on, for example, company HSE training and education, have yet to be developed.

Thirdly, and simply, the data to measure performance improvement has either not been generated or, if it exists, is not reported in readily accessible or standardized formats. The data gaps also reflect the fact that corporate HSE systems and programmes are highly varied, differing between companies, and even between national affiliates of multinational corporations according to the national context and culture. The need for better data collection is acknowledged by the industry. In CEFIC's 1997 RC report, for example, the president's message says:

Progress means taking a step forward and the CEFIC Board believes that now is the time to start collecting and reporting health, safety and environment performance data at European level. To this end a set of 16 core parameters has been adopted. This will take time to implement in full, but this year [1998] we are taking that first step.⁽⁷⁾

Despite such difficulties, examples of the effect of VIs on company HSE training and education programmes can be found. The remainder of this section describes some of them.

3.2.1. Management training

It is clear that top, middle, and shop-floor management training and education on VIs are being addressed in most large companies, and increasingly in many SMEs as well. This extends to chief executive officer (CEO) level. Indeed, the Chair of CEFIC RC Committee says that one of the main benefits of RC is that it has made senior managers more aware of HSE, as well as making them realize they have to listen to constituents outside the chemical industry.⁽⁸⁾

The experience of Thomas Swan and Co. Ltd., an SME with some 150 employees and based in Consett in the United Kingdom, is illustrative of the impact of VIs on management and general training. The company manufactures a basic range of batch production chemicals such as disinfectants, peptides, etc., often under licence for other companies. It does not have a full-time safety, environment or training officer. Its main environmental problems are resource use, materials handling and waste.

In 1991, a management discussion on total quality management led to a decision by the company to put resources into British Standard (BS) 7750 on setting up environmental management systems, starting in June 1992. This led on to participation in the Responsible Care initiative. The site was subsequently EMAS-registered in December 1996. Further work is now under way on incorporating BS 8800, described as a health and safety management system with an environmental management system bolted on, and linked to ISO 14001. Responsible Care, however, is not a brand image within the plant and the management and workforce are unfamiliar with this term. Implementation of the British Chemical Industry Association's RC self-assessment and verification procedures is under way.

The company does more training than in 1991, and since 1995 especially has improved training and education programmes, which now cover everyone on site, including contractors. The firm now employs more qualified personnel, and middle management personnel are taking Open University training courses on HSE. There is also management experience training in the form of attendance at seminars and workshops. There is greater awareness training throughout the company, and more retraining to improve process operation procedures, both formal and informal. An environmental training needs plan resulted from the BS 7750 exercise, and a training needs database has been developed.

Process operator training, for example, starts with four induction training courses lasting four hours each. Refresher training courses are regularly held and three process managers are responsible for organizing and running the sessions. Operators are also encouraged, on a voluntary basis, to participate in modular training courses on chemicals HSE run by the Cleveland Open Learning Unit. Each module lasts one year, with a visit from a tutor once per month. As of April 1998, 14 operators had qualified to level 1 (first year) and ten were working to pass level 2.

Swan's training activities have extended to other companies. Some 20 companies have asked for its advice on HSE management training, and representatives from these firms have visited Swan's plant and been shown its standard HSE training package.

The company, however, acknowledges that regulations have also been important in increasing the amount and types of training. In particular, the Integrated Pollution Control (IPC) Regulations, made under the United Kingdom Environmental Protection Act, provides a legal basis for much company training, along with the Control of Substances Hazardous to Health (COSHH) Regulations, made under the Health and Safety at Work Act.⁽⁹⁾

An example from the French chemical industry in respect of professional training is the work of the Collège National d'Experts en Environnement de l'Industrie Chimique, an organization created by the French Chemical Industry Association (UIC) and eight companies to promote professional qualifications in the field of environment. The college held two four-day training courses in 1997 for experts from the chemical industry.⁽¹⁰⁾

In the southern hemisphere, the Australian Plastics and Chemical Industries Association (PACIA) conducts an ongoing series of training courses for industry managers and key employees on the use, handling, storage, transport and information requirements of chemicals, especially linked to RC. In the 12 months to June 1997, for example, a total of 33 courses were conducted in all mainland state capitals, attracting 306 participants.⁽¹¹⁾ Also in 1997, to further assist member companies to implement their programmes, the Association published a list of providers of training courses in RC skills, lists of available videos on various aspects of RC and guidelines for linking the programme to the ISO 9000 and ISO 14001 international quality and environmental management standards.⁽¹²⁾

Education and training for environment and safety in the Yokkaichi plant (1,000 employees) of the Tosoh Corporation, Japan amounts to some 11,690 work-hours per year, or approximately 0.6 per cent of the 2 million work-hours worked per year; 7,310 of those work-hours were devoted to environmental preservation, process safety and disaster prevention.⁽¹³⁾

3.2.2. Blue-collar worker training

The impact of VIs on training and education for blue-collar workers is less well documented. Little information was available concerning the identification of training needs and programmes that respond to those needs for this category of workers. This contrasts with the situation for general technical training in the industry, where the 1995 ILO report noted that "union participation with management in determining training policy is increasing, and nearly all training agencies are now tripartite in structure".⁽¹⁴⁾ According to the ICEM statement in box 2.4, this would not appear to be the case for training related to VIs. A comprehensive South African training survey has highlighted the need to improve blue-collar training, as well as management and contractor training. Although the survey did not deal exclusively with chemical manufacturing or chemical-using companies, the findings are indicative of how HSE training could be improved. The South African Human Sciences Research Council (HSRC) carried out the survey in 1997 to establish a national perspective of the state of environmental training in the workplace. This identified compliance with legislation and ISO 14001 as the main drivers for HSE training, while the limiting constraints were money (no budget allocated), time factors, lack of information, training materials, courses and guidelines, lack of skilled trainers and difficulty in training unskilled and illiterate employees.

The target sample for the study consisted of 116 companies with 200 or more employees in three geographical regions -- Gauteng and the greater Cape Town and greater Durban metropolitan areas. The data were gathered in face-to-face interviews with representatives of the sampled sites.

The survey found that 56 per cent of the survey sites provided environmental training. The most common training for all employee levels was in the following subjects:

• HSE training;
• legal and company policy compliance training;
• general environmental awareness;
• waste management training.

The least common training for all employee levels was in these areas:

• environment-related public participation skills;
• environmental impact assessment and auditing methodologies;
• environment-related communication skills.

Of all the employee levels on site, contractors seemed to be the least exposed to environmental training.

Although 50 per cent of the sampled sites had environmental policies and slightly more than 50 per cent monitored their impact on the environment, the majority of the site spokespersons (81 per cent) believed their sites had little or no adverse impact on the environment, although in the view of the survey report's authors: "For environmental training to be effective, companies need to be clear about their environmental impact." The survey found that not only was there no standard approach to the environment or environmental training on sites but also that employees (or spokespersons at the sites) were not always sure whose responsibility it was to deal with environmental issues on the site. Of the total sample, 29 per cent of the sites had a separate environmental function and/or structure, while 51 per cent had an HSE function and/or structure. Only 50 per cent of the respondents in fact were convinced about the benefits of environmental training; 37 per cent of the sample actually agreed with the questionnaire statement that environmental training only adds to the training burden.

The survey also highlighted the need for new types of training for blue-collar workers especially for communication and public participation skills, reflecting the increasing involvement of the workforce with issues beyond the factory gate, and even with external auditors within plants.

The Canadian Chemical Producers' Association's (CCPA) "community right-to-know policy" is a cornerstone of its Community Awareness and Emergency Response (CAER) Code, which deals with relations between chemical plants and the neighbouring communities. This is explained by the CCPA as: "Simply put, if a CCPA plant is located near you, or ships chemicals through your community, it's your right to be told about all the risks you're exposed to. It's your right to ask tough questions and to expect clear answers."⁽¹⁵⁾ This demands new attitudes and skills in a company's workforce -- at all levels.

To meet such needs, the Chemical Industries Association (CIA) in the United Kingdom encourages communication training. Its responsible neighbours publication notes that: "Every site will have contact with the news media and the public and must provide training for people who communicate with these audiences or who participate in community relations activities."⁽¹⁶⁾

Non-traditional techniques can also be used for blue-collar training. In South Africa, the general education level of the workforce is low and training needs to be appropriate to this, in many cases requiring translation of the training materials into various local languages. Some companies are now using industrial theatre to aid understanding. Actors go into the factory environment using minimal props to discuss and enact a theme, emphasizing the relevant points in the appropriate languages. The approach has been well received. One local company, Blue Moon, has done general courses on such themes as the Occupational Health and Safety Act, and customer service, as well as tailor-made company courses. The South African Chemical Industry Association (CAIA) is investigating the possibility of using this medium more widely. It is, however, expensive and would require industry resources to develop for more general use.⁽¹⁷⁾

One large South African company, Polyfin, reported that in addition to their routine HSE, first aid and personnel hygiene programmes, they have now adopted a behaviour-based safety initiative called BAPP(R) (behavioural accident prevention process). The process was developed by BST(R) (behavioural science technology) and is employee driven at the shop-floor level. Behaviours critical to safe working are identified, employees are trained in these behaviours and observations are performed by the workers on each other. They try to identify these behaviours during the observation and then provide their fellow workers with feedback. After one year's experience, the method had shown excellent results. The process works on a "no name no blame" principle, so no one can be disciplined as a result of the exercise. This company also has an environmental centre, manned on a 24-hour basis, where HSE training is given as part of the two-day induction programme for new employees.⁽¹⁸⁾

An example from the United States chemical industry highlights the need for more audit/verification training. In 1997, the CMA, which was starting work on company self-assessment and third-party validation, found that there were not enough trained verifiers to handle more than a few company-level management system verification (MSV) exercises. It began staffing up to carry out MSVs on 40-50 companies per year, or almost one a week.⁽¹⁹⁾

3.2.3. Trade union/worker representatives

Worker and especially trade union HSE representatives and HSE committee members are an important category who require special training and education if the effectiveness of VIs is to be maximized. Some companies have their own joint (management-staff) HSE bodies. It would be useful to know more about the role they play in VI training and education, in particular the extent to which employers provide training and education specifically for workers' leaders, HSE representatives and works council leaders in VI matters and with what results.

The experience of Velsicol Chemicals in the United States is one example which highlights the benefits of trade union involvement. At the company's Chattanooga facility, and using the Responsible Care Employee Health and Safety Code as a "catalyst", Velsicol and its local union have implemented a programme called the United Safety Alliance, a joint union-management programme to provide new, meaningful ways for all employees to participate in safety. The Alliance fulfils one of the goals of the Employee Health and Safety Code: involving workers in safety efforts. The Alliance provides for hands-on involvement of employees in all facets of safety and prevention. Since 1995, the facility has dramatically reduced lost-time injuries and recordable injuries as defined by the Occupational Safety and Health Administration (OSHA). During the period 1997 to mid-1998, the plant did not suffer from a lost-time accident and had only one recordable injury.⁽²⁰⁾

3.2.4. Contractor training

Contracting out of tasks is on the increase in the chemical industries. Driven by concerns about productivity and competitiveness, the use of contract labour has become more prevalent in many countries in recent years, although it is less common in production-related activities than in capital projects and site services (transport/distribution, maintenance, office cleaning, canteen, security, etc.). This change in employment patterns has major implications for training, especially where the contractors or subcontractors are of a short-term nature, which makes it more difficult for companies to provide consistent training and to ensure that high standards are achieved and maintained.

Growing attention is therefore being paid to contractor training and auditing/certification. The Netherlands Chemical Industry Association (VNCI) has taken a lead in tackling this issue in the light of the realization in the early 1990s that the rate of accidents for contractors was much higher than for the chemical companies' own employees. To combat this deteriorating safety performance related to the increased use of contractors on site, a number of chemical companies began using their own checklists to judge if a contractor was complying with HSE requirements.⁽²¹⁾ These company checklists were the basis of a uniform contractor safety auditing certification system, the Safety Checklist Contractors (SCC), devised by the (VNCI) and finalized in 1994.⁽²²⁾ One of the conditions of certification is the company obligation to constantly train contractor management (and ultimately the workforce -- see below). By 1998, over 3,500 contractors have been certified by independent accredited certification bodies in the Netherlands, Belgium and Germany, with others in France and the United Kingdom following suit. The SCC certificate is valid for a three-year period.⁽²³⁾ In principle, the CEFIC has accepted the SCC system for use at the pan-European level.

Two certificates exist:

• Limited -- intended for companies employing fewer than 35 workers, and aimed at safety-related control of shop-floor activities.
• General -- intended for main contractors in the petrochemical sector and covering safety management structures within the contractor company.
• Areas covered by the limited and general certificates include:
• safety education upon entering employment; and
• safety education of supervisors.

At the moment, VNCI is trying to get contractor education and training levels raised. A set of training manuals has been developed, and by the year 2000 contractors seeking certification will have to have trained all employees working on chemical sites. At present only managers have to complete the training courses.

The Netherlands system has now evolved into a system of "contractor passports", whereby an individual contractor (as opposed to the company) has a certificate, a "passport", which enables the holder to move freely between companies on the basis of an accepted competence accreditation. The contractor passport system has also evolved elsewhere, often on a local basis. Companies, for example, around the Humberside Estuary in the United Kingdom have introduced a local contractor passport scheme based on common training standards and certification.⁽²⁴⁾

Under New Zealand's RC programme, employers engaging contractors have an obligation to protect them. The New Zealand Chemical Industry Council (NZCIC) has developed guidelines for managing contractors which include provision for training. The guideline on training aims to help a potential contractor qualify for recognition as an "approved contractor", and outlines the subjects on which a company may wish to offer short but comprehensive training.⁽²⁵⁾

In the plants of BP Chemicals UK, contractors and company employees participate side by side in the same HSE training and education courses. The result is that both groups are trained to common standards and methods. Sharing experiences and working jointly on problem-solving exercises can also help overcome the historical problem of contractors sometimes being treated as second-class citizens by company employees. Training courses are also held for BP staff responsible for managing contractors. In 1997-98, the BP plant at Saltend, Humberside, held two courses per week over a ten-week period, which 250 people attended.⁽²⁶⁾ Furthermore, at BP's Baglan Bay plant in South Wales, contractors participate in the company HSE committee.⁽²⁷⁾

3.2.5. The role of small and medium-sized enterprises (SMEs)

Conventional wisdom often says that VIs are more suited to large companies, especially multinationals, with professional HSE staff, company (and often corporate-wide) training and education programmes and adequate financial resources. However, as the following examples show, VIs are also capable of improving HSE performance in SMEs. Increasing numbers of SMEs in both developed and developing countries are benefiting from, and playing active roles in, VI programmes worldwide, especially in respect of training and education.

The Chemical Industry Federation of Finland (KT) launched its national RC programme, entitled Vastuu Huomisesta, in 1992. Eighty-seven member companies covering more than 80 per cent of Finland's chemical industry (measured by volume of production) have committed to the programme. Most of these companies are SMEs. The smallest has ten workers. Twenty-two per cent are classed as major companies with more than 250 employees, 34 per cent are small enterprises with fewer than 50 employees and 44 per cent are medium-sized enterprises. The RC programme is the same for all companies but to make it easier for SMEs to start implementing the programme, the Federation prepared a booklet and five self-assessment guides designed especially for those companies.⁽²⁸⁾

RC can be part of the HSE learning curve for SMEs. In 1993, when external verification began under the Canadian RC programme, Sulco Chemicals, with 19 employees and limited resources, volunteered to be the first to be verified. Although it did not succeed on its first try (the problem was community awareness), the company had a successful verification in 1996.⁽²⁹⁾

Lubrizol Canada, a small Niagara-based blender of lubricant additives, also failed its RC verification. Despite the company's long-standing involvement in the local community, the Canadian Chemical Producers' Association's (CCPA) verification team found that the company had not adequately defined its worst-case scenario and communicated it to the public. With input from the CCPA verification team, Lubrizol's risk assessment team investigated 20 scenarios. One of them, previously dismissed as low risk, turned out to be the company's worst case: if overheated, one of the company's additives could decompose and generate hydrogen sulphide, a gas noted for its toxicity and odour of rotten eggs. Lubrizol responded by inviting a cross-section of the community to its first community advisory panel meeting to explain the worst-case scenario and their efforts to control that situation. They also presented the worst-case scenario to local emergency services, with whom they had to drill to test emergency response plans. Finally, the company's manager went door to door, presenting the information personally to the company's closest neighbours.⁽³⁰⁾

RC can help SMEs develop their management structures and training programmes. This is the experience of Eaglebrook, an SME in the United States with about 200 employees and six sites. The company produces and distributes ferric chloride and ferric sulfate for water treatment applications. The company admits there was a lot of catching up to be done on RC implementation, especially in incorporating the programme's highly structured management practices. The firm's CEO says: "If you're a small, entrepreneurial company you don't always have goals and objectives and benchmarking procedures." It was not used to operating with performance management systems which made it hard to implement the programme. The biggest changes for the company have been in distribution -- in training, selection of carriers and increased use of commercial terminals. For the company there is a cost to being an RC company that is not borne by firms that do not follow the programme. For Eaglebrook, the main additional costs have been in distribution, some process design at plants and the addition of a salaried employee to administer the programme. The CEO says, however, that with RC: "You're tying into one of the best HSE programmes in the world", and he sees major benefits to a small firm coming from the ability to get access to the best practices in the industry set by leading firms.⁽³¹⁾

RC can also be relevant even for the smaller subsidiaries of large corporations. At the American affiliate of Bayer Corporation, one of the benefits of RC has been the development of a single, encompassing HSE standard to apply to all its sites. The parent corporation said that while the company's larger plants would have operated or exceeded standards set under RC, bringing smaller and acquired units to that level would have been difficult in the absence of an initiative such as RC. It provided a framework to bring all the company facilities to the same high standard.⁽³²⁾

Some national trade associations are also providing assistance to SMEs in other countries. The German Chemical Industry Association (VCI) is running a know-how transfer programme to SMEs in the Czech Republic and Hungary. The programme provides coaching and training to SMEs to help them implement management systems using RC and ISO 14001. The project is financed by the VCI and organized by its environmental advisory service (CUB).⁽³³⁾

3.3. Trade association training and education activities

To ensure that HSE standards are raised across all sectors of the chemical industry, trade associations have assumed central roles in the promotion and implementation of VIs especially on awareness-raising activities for the industry as a whole, and in the application of guiding principles, codes of practice, performance indicators, self-assessment and verification and so on at the company level. In addition, they have played important roles in external communication and media work on VIs and in stimulating VI partnerships with other industrial sectors. The role of trade associations in developing countries has also been of critical importance.

To carry out new functions and reinforce ongoing HSE activities, associations have had themselves to develop new training and education approaches and activities. Training and education is required for:

• trade association staff;
• member companies including CEO/board level personnel;
• affiliates, partner organizations, and non-member companies;
• others, such as specialized institutes associated with or financed by industry (e.g. educational trusts, toxicology laboratories);
• audit/verification staff.

3.3.1. Industry awareness raising

Awareness-raising seminars are a definite feature of VI training and education. Most national associations, for example, carry out awareness-raising seminars on VIs, involving the chemical industry and often other stakeholders. In addition, regional bodies also hold seminars. In the Asia-Pacific region, annual RC conferences have been held since 1995. In May 1998, the Taiwan Responsible Care Association (TRCA) hosted the fourth annual Asia-Pacific RC Conference, with some 350 industry representatives from 13 countries, in addition to a number of government and academic guests. The Conference aimed to facilitate information exchange between country associations and raise general awareness of RC in the region.⁽³⁴⁾

Similarly, CEFIC's regional RC workshop is an example of an annual awareness-raising event aimed at continuous improvement and sharing experience within the chemical industry in its 21 European associations which participate in RC. The 1998 workshop dealt with product stewardship issues, discussing strategies and identifying products that needed to be addressed.⁽³⁵⁾ It targeted business managers, a challenge in itself as many of them were apparently not yet convinced that RC was the right thing from their perspective.⁽³⁶⁾

The French Chemical Industry Association (UIC) has held a series of national and regional seminars within France to help raise awareness among and to train the industry people involved in RC. To promote product stewardship, a UIC national workshop was held in October 1997 on the risk management of chemical products. In the same year, a series of regional conferences related to HSE issues were held. These conferences organized by UIC local chemical associations concentrated on the implementation of RC at regional level and on feedback from experience by presenting various practical activities undertaken by chemical companies.⁽³⁷⁾

National workshops can also have an international flavour. The South African Chemical Industry Association (CAIA) held a product stewardship workshop in 1998 where international speakers brought new perspectives. Describing the workshop as a success, CAIA's RC manager adds:

I do believe that Responsible Care since its launch in 1994 in South Africa has done much to raise awareness in both the chemical and support industries, particularly amongst the smaller companies by informing and involving them in:

• all of our new legislation processes;
• holding discussion and working groups;
• running workshops at the three major centres Gauteng, Durban and Capetown several times a year.

But she adds, "it is difficult to measure the improvement that is attributable directly to Responsible Care".⁽³⁸⁾

Scandinavian chemical associations have played a leading role in promoting training and education as part of RC. The Chemical Industry Federation of Finland (KT) says that the training of employees in Responsible Care companies in environmental protection and safety has continuously increased. The percentage of employees participating in training has soared from about 30 per cent in 1988 to some 70 per cent in 1996.⁽³⁹⁾ The Federation's latest activity in the field of training and education is a project with some companies and institutes to develop a systematic approach to training methods for companies. It is based on the fact that companies offer training to acquaint personnel with the company's environmental, health and safety initiatives, future targets and practical measures, and to motivate them to perform responsibly in their own work. Since companies often give the same kind of environmental protection and safety training, it was decided in 1996 to seek cooperation with educational institutions. A plan will be drawn up to assist translation of the principles of Responsible Care into practical measures and to ensure that personnel are committed to the same goals. The Finnish enterprises committed to RC have expressed their training and education needs related to HSE issues. Training is needed by the entire personnel in the company. The collaborative project "Environmental, health and safety training in an enterprise" aims to turn the company's commitment to RC into practice in daily activities at the workplace. The project develops a training programme which consists of all fields of the RC programme. Developing positive attitudes towards HSE activities is a high area of priority. The project is funded by the Finnish Work Environment Fund from November 1997 to June 1999. Partners are the Chemical Industry Federation of Finland, Finnish Institute of Occupational Health, Espoo-Vantaa Institute of Technology and five RC-committed companies (pilot enterprises).⁽⁴⁰⁾

The Association of Swedish Chemical Industries (Kemikontoret) regards a well-trained and skilled workforce as a fundamental requirement for companies and as an important part of the RC commitment. The Association reports that:

The fact that heavier emphasis is now laid on staff training is also illustrated by the fact that [RC-related] training inputs at the 32 companies that issued reports in 1990, 1994 and 1995 remains at a higher level for 1995 compared to 1990. The average for 1995 is well over four days per employee a year. For all companies the average is approximately four days per employee per year.⁽⁴¹⁾

It further reported that: "Training programmes at the 34 Swedish companies that issued reports in both 1990 and 1994 increased with respect to time spent, on average, from about four days to about six days per employee a year."⁽⁴²⁾

The Federation of Norwegian Process Industries (PIL), which covers 14 industrial sectors including various branches of the chemical industries, reports that a major result of phase 2 of RC, initiated at the end of 1996, was improved HSE education at all organizational levels in the industry. There would also seem to be spin-off benefits for non-chemical sectors. In 1993, a working group (formalized as a permanent RC committee in 1996) was established to examine all training literature used for the training of operators, foremen and middle management for the process industries. The conclusion was that it was all outdated. The group then set out to define and formulate the training needs and possible content of a new training programme and delivered its recommendations to the PIL training and education college in 1997. As a result, the contents and printed support material of various courses have been revised and new material produced. The first new courses covering different industrial sectors were due to take place in 1998.⁽⁴³⁾ The training is offered in a variety of ways, from short courses to distance learning. The training is directed towards upper management, foremen and operators - but specialist seminars may follow. In 1998, the Federation developed a mail-based training programme on "Chemical risks and safe handling of chemicals". The primary target group is operators in the chemical industry.⁽⁴⁴⁾ Another spin-off of the group's work is trying to define the absolute minimum HSE knowledge a person should have before being licensed to take up any position in an industry. A further spin-off is a recent project (1998-2000) where PIL, Hydro and Statoil will develop an IT-based interactive basic training programme in HSE.

After a slow start, the work of the Japan Chemical Industry Association (JCIA) on RC has quickened in pace. The Japanese Responsible Care Council (JRCC), founded in 1995, assists member enterprises in effective RC programme implementation by organizing seminars on topics such as preparation of material safety data sheets, risk assessment, and proper handling of chemical substances. It also targets non-member enterprises to try and increase the JRCC membership. More than 60 RC seminars have been held since 1996 with over 6,000 participants. In particular, the Council held regional RC meetings at nine major petrochemical complexes, with a total of over 1,000 participants from local government, JRCC member and non-member companies, industry associations, trade unions, and the media.⁽⁴⁵⁾ In its 1996 annual RC report, the Council said that most member companies had almost completed their RC management systems, with 97 per cent having established an internal audit system. As part of the management systems, members were establishing in-house education systems and implementing RC awareness education. The Council observes that: "Members should recognize the importance of education and actively promote it at every opportunity."⁽⁴⁶⁾

Most of the HSE training and education is provided at enterprise level. The JRCC judged that 89 per cent of its member companies were meeting the implementation standards concerning education of employees on RC in 1995. In 1996, 55 per cent of companies replied to the JRCC that they had completed or nearly completed in-house education systems and 40 per cent stated that they were in the process of establishing such systems. In general, companies provide initial training for newly recruited employees. Further training is provided at each level of occupational status. HSE is an element in this training and has been attracting more attention since the introduction of RC.⁽⁴⁷⁾

At the shop floor, on-the-job training, supplemented by various manuals, is provided for plant workers about safe operation. Of particular interest is what is termed the "Hiyari-Hatto" circle activity. Plant workers exchange their experience on imminent dangers of accidents and single out possible ways to prevent them. This activity takes place in each business unit within an enterprise as well as at regional level. In order to prevent major industrial accidents, member enterprises establish an in-house communication network, prepare manuals to cope with such accidents and do periodic emergency drills. Contracting companies and the local community, as well as company staff, sometimes participate. The member enterprises also try to improve HSE standards of contractors, checking their operational situation and/or providing training for the workers concerned.

Whilst these activities are not new, they are now incorporated into a company's RC programme, and as a result the JRCC believes that companies and their employees take HSE more seriously than before. The Council claims that the following changes can be observed after the introduction of RC activity. Firstly, the companies are trying to enhance their employees' awareness of environmental matters at each operational level by showing them the company's environmental initiatives. Secondly, it is estimated that the targets and the frequency of training on HSE are rising. Thirdly, workers can have access to many documents such as material safety data sheets (MSDs) and are well acquainted with the characteristics and hazards of the chemical substances they handle.⁽⁴⁸⁾

Trade associations in Central Europe have been active in promoting RC. Up to May 1997, the Polish Chamber of the Chemical Industry (PIPC), in association with the Industrial Chemistry Research Institute (ICRI), had held three RC progress workshops. Thirty-one people, including 26 from 16 major chemical companies, participated in the third workshop in 1997 on the theme of reducing the impact of the chemical industry on the environment and in improving safety and health protection.⁽⁴⁹⁾

Similarly, the Association of Chemical and Pharmaceutical Industry of the Slovak Republic (ZCHFP) has held a series of seminars under the RC umbrella. An RC seminar in 1997 introduced the RC initiative mainly to heads of environment departments in chemical companies. It dealt with the current status, experience of RC, its benefits, implementation, its relationship to other environmental standards and integrated management system for HSE. An item on verification was presented by a representative of the British Chemical Industries Association. In 1998, a further seminar on RC and safety at work is under preparation, to which representatives of trade unions are to be invited.⁽⁵⁰⁾ The Association also reports that environmental issues and safety at work are integral parts of training of all employees and management. Each member company has an internal training plan with dates, topics, lecturers and target audience. Materials about the RC programme, its main features and indicators of performance have been provided to member companies to assist with the training. Special lectures are being prepared on the worldwide RC programme and how it represents a new ethic in business concerning manufacturing, distribution and trade with chemical substances.⁽⁵¹⁾

In Western Europe, the Italian Chemical Industry Association (Federchimica) regularly organizes RC training exercises. In 1997, six seminars were held on "crisis management" with a total of about 200 participants from industry. These sessions were conducted as realistic simulations of a major industrial accident. The participants were split between a local management room, a site management room with relations to external help providers and a communication room dealing with the press and communities. The Association also regularly publishes Responsible Care environmental reports. The third report covers the period 1989-96 and shows the trend of air and water emissions, waste production, energy and water consumption and health and safety indicators. Average improvement over this period was about 50 per cent.⁽⁵²⁾

In 1997, the Spanish Chemical Industry Association (FEIQUE) held six one-day workshops to train new RC coordinators in companies, principally site managers and technicians; 150 people attended in total, and the workshops were of great help in obtaining suggestions about overcoming the difficulties of implementing the programme.⁽⁵³⁾

Trade associations can also promote better sharing of data and information between companies as part of RC, helping to break down barriers between competing companies who can see themselves as rivals rather than allies. To facilitate such information and experience sharing, the British Chemical Industries Association (CIA) has established an RC cell network made up of chemical company representatives in a locality who regularly meet to discuss RC issues. Participants include site managers, HSE professionals and sometimes staff from personnel departments.⁽⁵⁴⁾ The cells cover a wide range of topics, sometimes discussing community as well as technical issues. Training and education activities of the cells include running two HSE training days for small companies and publication of a schools resources guide in the North Tyne cell, and involvement with a local Agenda 21 Initiative in the case of the Warrington cell.⁽⁵⁵⁾ In addition, since 1988 the CIA has held 18 RC seminars to raise awareness in the industry -- 75 per cent of sites now have active links with local communities; 66 per cent of sites produce environmental reports for which employees represent 43 per cent of the audience.⁽⁵⁶⁾

3.3.2. The role of trade associations in developing and rapidly industrializing countries

There are particular problems associated with VIs in developing countries which often lack the legislative framework, infrastructure and enforcement capacity for the sound management of chemicals and may be faced with major health and safety and pollution problems from earlier patterns of growth.

One issue, the relationship of regulation to voluntarism, is highlighted in a comment by an Indian Government official, who was fully informed about the concepts of Responsible Care, but was of the opinion that the chemical industry in India had a long way to go before it could take up those concepts for implementation. At present, she would be satisfied if the minimum compliance with regulations were attempted.⁽⁵⁷⁾ In particular, a disaster in 1997 at the petroleum refinery in Visakhapatnam appears to have shaken her Ministry's confidence in the ability of even modern, large industries to manage routine procedures for pollution prevention and safety.⁽⁵⁸⁾ Her concerns appear to be shared by the Chairperson of the Responsible Care programme of the Indian Chemical Manufacturers' Association (ICMA). He has stated that the Responsible Care movement in India has been slow to gain acceptance from the chemical industry since it was set up in 1993, and the Association's current priority was obtaining more commitment at executive level. The Association has not yet permitted the RC logo to be used by any Indian firm. He believes that 50 to 60 per cent of the 52 signatory companies (representing more than 70 per cent of Indian chemical production) have implemented the three prioritized codes on process safety, employee health and safety, and pollution prevention, which include training elements. However, he acknowledges that this figure is an estimate, since only a few of the companies have reported to the Association on the level of implementation of the codes, although self-evaluation is supposed to be one of the key elements of RC with members and partners having to submit reports annually on their progress in implementing each of the codes. But there has been a dearth of data. "What is difficult to understand", he says, "is the hesitation and reluctance of the signatories to make information available, a fact which runs against the spirit of the RC programme which advocates dialogue with all stakeholders". Response from the signatories, he added, "has yet to reach critical mass or significance".⁽⁵⁹⁾

There have been some voluntary initiatives taken by Indian companies, dealing with pollution prevention and worker protection, for example. A report commissioned by the ILO found ten examples from six cities, based on walk-through surveys in March-April 1998. All of these units are large companies, and five of them are associated with Western manufacturers. Only one has ISO 14001 certification, while none has adopted RC. Thus, these voluntary initiatives do not appear to have been sparked off by a conception of Responsible Care.⁽⁶⁰⁾ At some of the sites visited, HSE problems existed for which training was part of the solution. However, despite apparent management commitment to correct the problems, progress was very slow.

Another difficulty in some countries is the lack of identifiable bodies with sufficient resources to lead a voluntary programme. In the Republic of Korea, for example, a spokesperson for the Korean Petrochemical Industry Association (KPIA) noted that with five associations representing different arms of the chemical industry, a systematic RC programme cannot be developed. KPIA developed six management codes in 1993 but a single body representing the chemical industry was needed to organize and manage the programme. He noted that many multinational chemical companies (MNCs) operating in his country were very interested in beginning an RC programme. He believed that discussions with local companies based on MNCs sharing their experiences on voluntary initiatives could be "a catalytic element to come up with ideas to overcome the cultural gaps in starting RC linked to regular communication with community representatives for building up consensus in the community".⁽⁶¹⁾

The comments from the KPIA on MNCs sharing their experiences with local companies link up to suggestions on the concept of "mentoring" put forward by the Chairman of CEFIC's RC Committee when addressing the industry's Asia-Pacific RC Conference in 1998. He stated that:

Here in Asia, we recognize that we have local chemical companies working alongside multinational companies. This provides the opportunity for close working relationships to develop Responsible Care to reflect both international standards and local culture ... There are some excellent Responsible Care programmes being developed here in Asia. This region also presents us with the opportunity to foster the development of another concept -- mentoring. By this I mean large well-resourced chemical industry federations helping and supporting smaller, less well-resourced federations, and large chemical companies helping their smaller brethren in the areas of safety, health and the environment so that the performance of the total industry improves ... We can gain great strength from "mentoring" which is coaching and support, not telling or dictating.⁽⁶²⁾

Governments in these countries can also play a critical role in fostering VIs. The Chemical Industries Council of Malaysia (CICM) aims to introduce six RC codes by the end of 1999. These codes have been drawn up by code development teams drawn from CICM membership. Outside input has also been sought for the three codes introduced to date -- from a logistics consultant for the distribution code, the Malaysian Department of Safety and Health for the employee safety code, and the Malaysian Department of the Environment for pollution prevention. Government agencies have also helped spur interest in the codes by attending the CICM's regional meetings held for training purposes related to the codes. Responsible Care is being developed alongside strong chemical safety regulation. Emergency scenarios as well as environmental impact assessments must be prepared for chemical industry developments. Chemical companies keen to learn about new regulations have attended the regional meetings to talk to agencies -- the link between regulation and Responsible Care is proving positive.⁽⁶³⁾ In Taiwan, China, the Taiwan RC Association (TRCA) also acknowledges that its RC efforts have strongly benefited from the active and enthusiastic support of the Ministry of Economic Affairs Industrial Development Bureau.⁽⁶⁴⁾

Taiwan, China also illustrates the need to consider the legacy of past unsustainable growth in setting up voluntary programmes. It was one of the Asia-Pacific region's first "tigers", with strong chemical industry growth based on cheap labour, available land, limited regulatory restrictions and a strong domestic market. But as the Chair of the TRCA noted at the 1998 Asia-Pacific Responsible Care Conference: "This growth came at a steep price ... [and] ... Neighbour protests and poor public image are spiralling and threaten new investment and growth."⁽⁶⁵⁾ The creation of TRCA was seen as a necessary first step to improve the industry's performance and image. One of the lessons learned was that "the growth of RC ... will require taking risks and increasing education on a large scale".⁽⁶⁶⁾ To this end, association members now seek greater cooperation in many areas, such as shared contractor training programmes and performance reporting standards. Furthermore, in 1998, the Association is working to establish regional RC training programmes and industrial park leadership groups around the island.⁽⁶⁷⁾

Start-up costs of voluntary programmes can also be a barrier. The Chemical Industries Club of Thailand (CICT) faced this problem when it requested RC membership and permission to use the RC logo from the ICCA. To facilitate its entry (which is still pending), the Club formed an RC steering committee in 1996, which was reorganized in October 1997 by integrating representatives of multinational companies in order to gain better access to resources and networks. Three RC awareness seminars were held in 1997-98, with a further three planned in 1998-99. An important element of RC implementation in the future will be training the members regarding the COP in order to have knowledge for implementation.⁽⁶⁸⁾

A unique problem facing the Mexican Chemical Industry Association's (ANIQ) RC programme implementation is that the state-owned oil company Pemex is both supplier to and client of many of the Association's members, and has no RC programme. Without the participation of Pemex's petrochemical division it is difficult to make comprehensive HSE improvements at the national sectoral level. ANIQ began implementing RC in 1994 and a commitment to RC is a condition of membership of the Association's 215 companies. It expelled 17 companies in 1997 for failure to adopt the programme. The Association is helping members in their implementation efforts by providing training and management assistance.⁽⁶⁹⁾

Also in Latin America, the Chilean Chemical Industry Association (ASIQUIM) promotes training programmes developed by other institutions and has created a series of activities on management training and development. From 1996-97, the Association held nine training and awareness-raising sessions on a variety of HSE themes linked to RC.⁽⁷⁰⁾

3.4. Chemical distribution/supply training and education

Under VIs, companies and trade associations in both chemical manufacturing, distribution and use are aiming to raise awareness about HSE impacts over the whole life cycles of their products, and the need to produce, transport, distribute, store, use and dispose of them in a safe and environmentally acceptable manner from "cradle to grave/birth to reincarnation". Training and education is required for:

• business staff in the companies -- sales, marketing, purchasing, financial;
• staff including transport personnel;
• distributor trade association staff;
• supplier staff and supplier trade association personnel.

In many instances, improved distributor/supplier HSE performance is being achieved by extending established training and education activities on subjects such as transportation accidents and emergency response. In other instances, manufacturers are working in new ways with suppliers, distributors and customers in programmes and activities that go under the heading of "product stewardship", dealing with HSE through the whole life cycle of a product. Product stewardship is an area in which many companies are changing the way they communicate with customers. In particular, it involves new roles and training for the business staff in companies, in addition to the technical personnel, as well as training, education and awareness-raising activities along the supply distribution chain.

3.4.1. Transport

An example of transport training comes from a new ICI site in Taiwan, China which wanted to ensure the safe transport of chemicals requiring almost 200 road vehicle movements per day. A transportation risk assessment report produced in 1996 on this operation concluded that the risk to a driver is almost 1,000 times higher from a road traffic accident than from a chemical spillage incident. The results of the study emphasized the need for a special focus on procedures, training and choice of third-party contractors to offload ships, store raw materials, deliver finished product, load road tankers, and transport these to and from Kuan Yin. ICI adopted a Responsible Care approach to the issue, requiring the three companies in question to demonstrate a commitment to investment, training and providing resource for the operation, and to obtaining IS0 9000 accreditation. Other criteria included an assessment of their management organization, HSE performance and equipment suitability. In the first three years of operation there was considerable involvement of people in site safety programmes but limited success with the hauliers. A team was then established to raise the commitment and involvement of hauliers in improvement programmes, with successful results. Logistics contractors are now fully involved and enthusiastic about the new ICI approach. The experience and credibility gained in this exercise was used to generate the first Responsible Care code of practice on transportation.⁽⁷¹⁾

Related to this, the Director/HSE for the Formosa Plastics Corporation said that:

In addition to vehicle safety equipment, maintenance and inspection, it is necessary to educate, train and audit transportation companies and their personnel. Matters cannot be left to chance; practical training and auditing are the best guarantee of transportation safety.

His recommended guidelines for education and training included: engaging good instructors who possess hands-on experience and expertise; emphasizing the key cause-and-effect relationship between transportation and other operations; discussing actual disasters; reinforcing course content with hands-on interactive learning and drills; and converting key points in the transportation process into easily remembered ditties or cards to help transport personnel to remember them. In his view, auditors should attend the same training courses as transport personnel in addition to those on audit methods, and must be familiar with all work procedures, laws and regulations. Furthermore, audits should be stringent, all problems must be recorded with dangerous abnormal behaviours remedied immediately and recorded. He also suggests that incentive and penalty standards should be set and applied in accordance with audit results to instil pride in transport personnel.⁽⁷²⁾

The "zero defect delivery programme" of Nalco Chemicals in the United States was begun in 1987 to improve deliveries to customers. In 1990, 3 per cent of the company's deliveries resulted in an incident report from the company's customers or sales representatives, indicating dissatisfaction with the delivery from a safety or other customer satisfaction perspective. This percentage has steadily decreased since, and in 1997 only four-tenths of 1 per cent of deliveries were the subject of incident reports. Nalco's programme has been incorporated as an integral part of the Responsible Care® Distribution Code implementation and its ALERT emergency response system. The "product stewardship training module" is used to train all of Nalco's field representatives. The introduction to the training module is provided by the company.⁽⁷³⁾

3.4.2. Product stewardship

Product stewardship is one of the new subjects associated with VIs. It means:

Taking into account all health, safety and environmental aspects of a product during its entire life cycle, that means quality from cradle to grave. It is a new sense of responsibility that does not end when the product leaves the plant. Rather, product stewardship starts with research and development, continues in production, transport and storage, includes consumption and recycling and does not end before final disposal.⁽⁷⁴⁾

A number of national chemical industry associations that have subscribed to RC have adopted or are developing codes of practice on product stewardship.

It is proving to be one of the most ambitious aspects of RC because it requires companies to take responsibility for others' use and handling of their products. In the United States, it was the last code adopted by the CMA, and is unique among the six RC codes in that it introduced a management practice that had not previously existed in any structured form at most companies.⁽⁷⁵⁾ Recognizing that the code is the least implemented RC code, the CMA has promoted application of the code by members and partners by developing key resource materials and carrying out training programmes. A third implementation workshop was held in October 1997 with more than 150 participants representing half of CMA's member companies.⁽⁷⁶⁾ Implementation is further complicated by the pressure on the industry to increase product testing and make the data publicly available. According to the chief executive officer (CEO) of Hercules Chemicals in the United States, "Collecting safety data and communicating it to customers is the most challenging part of product stewardship. Most companies are struggling with that, and we're no exception."⁽⁷⁷⁾

Some American environmental groups say that the CMA has to do a better job of reaching small chemical customers. The Resource Technologies Group (RTG), for example, says that product stewardship outreach programmes have not reached small chemical customers in its area. A spokesperson for the group says that:

As community awareness increased over the past year [1997], several chemical customers, including food processors and electronics companies, hired consultants to identify environmental problems caused by the chemicals they use ... They aren't aware of product stewardship or CMA, so they hire us [RTG] to find answers for them.

RTG says that its clients do not always have direct contact with chemical producers. "Most of the time they buy chemicals from distributors who don't always practice product stewardship or know about", so the company has to contact chemical manufacturers to get product information for its clients.⁽⁷⁸⁾

In order to facilitate communication of product stewardship within companies, to customers and the community, some companies in the United States are increasing their training programmes in this area. Ashland Chemicals, for example, began a three-part training programme in 1998. The first phase is designed to train the heads of each operating division on product stewardship. The second part involves training employees within each division. The third addresses specific information on the products.⁽⁷⁹⁾ Union Carbide is taking time to educate customers by getting more involved in their daily operations to ensure they are using products safely.⁽⁸⁰⁾ PPG industries starts by training its employees on how to use the products through courses and written information. From there, the employees train the customers. Its coatings and resins division offers free training courses to its customers worldwide on how to properly handle the material.⁽⁸¹⁾

As these examples show, the concept is increasingly generating education and awareness-raising activities, many of which are targeted initially at chemical industry personnel, especially on the business side. This is also the case in Europe, where the concept has been slow to catch on. As CEFIC's RC coordinator says, "Product stewardship isn't well understood in Europe -- we're still at the stage of trying to convince those in the industry that they need to develop a product stewardship programme."⁽⁸²⁾ In the United Kingdom, the CIA's senior executive for RC adds that:

Raising awareness with the business community is the most pressing need for product stewardship. We must get the message across to business and commercial managers [that] implementing a focused product stewardship programme [has] demonstrable benefits in dealing effectively with health, safety and environment issues and strengthening links with customers.⁽⁸³⁾

National associations and companies are tackling product stewardship training, education and awareness raising in a variety of ways, and the role of the trade associations is particularly prominent in this area.

To stress the importance of RC in Germany, the German Chemical Industry Association (VCI) set up an RC Committee in early 1997. In October 1997, a VCI stakeholder workshop on RC was organized with participants from all relevant stakeholder groups. The outcome and recommendations of the workshop will be included in the future work of the VCI RC committee.⁽⁸⁴⁾ In 1996, the VCI "Product stewardship guide" was published as a support for VCI member firms, and in 1997 an information brochure "Criteria for product assessment" was published as an aid for the practical application of the guide. There is also close collaboration with the German Association of Chemical Distributors (VCH) on this issue.⁽⁸⁵⁾

In its Indicators of performance 1990-97 report, the United Kingdom CIA says it has developed a formal product stewardship training programme over the last three to four years (1994-98). A key component of this programme is an interactive workshop which focuses on managing product HSE risks/issues identified over the life cycle and examines best practices in developing and communicating solutions to customers and users. Case studies and syndicate sessions are used to demonstrate the practical consequences of stewardship action. Since 1995, over 200 delegates from member companies and other downstream chemical sectors have attended workshop sessions including many from business and commercial functions. A novel learning initiative in 1997 was a product stewardship information exchange, an event which facilitated the sharing of experiences, concerns and issues together with the interchange of practical stewardship solutions.⁽⁸⁶⁾ As one example of follow-up, Shell Chemicals reported to the CIA that it had organized a product stewardship workshop for distributors who market its organic solvents. The objective was to ensure that they understood the company's HSE policies and standards, to communicate product hazard awareness, address risk appraisal of customers' product reception facilities and promote the need for effective emergency response systems. The event used interactive syndicate sessions to help the distributors to appreciate how best to communicate product stewardship advice.⁽⁸⁷⁾

The Association of Swedish Chemical Industries (Kemikontoret) identified a need to inform sales representatives and purchasers in its member companies about product stewardship. The aim is to inform the companies' sales organization so that their customers get correct and sufficient information to be able to handle the products in a proper manner.⁽⁸⁸⁾ Five seminars were held with 250 people from some 50 companies attending. Many were from SMEs. The topics covered were: Legal requirements; Why does the customer need information?; Contents of information; What does the information mean?; RC and product stewardship; Waste; Transport; and the Need to do more than is legally required.⁽⁸⁹⁾ A third implementation workshop was held in October 1997 with more than 150 attendees representing half of CMA's member companies.⁽⁹⁰⁾

In some countries, formal agreements between manufacturers and distributors have been concluded. In 1997, the Spanish Chemical Industry Association (FEIQUE) reported that an agreement had been signed by Spanish chlorinated solvent producers, European producers with activities in Spain and their distributors, to achieve more effective management in the use of these products.⁽⁹¹⁾

Some companies, including SMEs, are also working with their suppliers to ensure that the products they buy from them are produced in accordance with VI principles and standards. Since 1995, Thomas Swan, an SME with some 150 employees in Consett in the United Kingdom, has been carrying out customer and supplier audits at an average rate of six per year as part of its EMAS commitment. The supplier audits deal with how suppliers manufacture the chemicals that Swan uses in its manufacturing processes. Auditing was at first seen by the suppliers as an unusual move but is now more widely accepted.⁽⁹²⁾

3.5. Outreach training and education

VIs have important dimensions beyond the workplace in providing outreach training, education and awareness raising for non-chemical industry people and organizations, and have posed new challenges for the industry. According to the Chairman of CEFIC's RC Committee and former Chair of ICCA's RC Leadership Group, one of the main benefits of RC is that "It has made bosses realize they have to listen to constituents outside the chemical industry".⁽⁹³⁾ This new awareness in the industry has in turn stimulated new company and trade association programmes and initiatives in this area. Awareness raising, training and education is required for:

• decision-makers involved with the chemical industries and/or its impacts -- emergency service personnel, regulators/legislators, planners and policy-makers;
• community representatives/groups, environmental non-governmental organizations, other civil groups;
• school/education services -- teachers and pupils, university/college teachers;
• media.

3.5.1. Community activities

As part of its RC programme, the Australian Plastics and Chemicals Industries Association (PACIA) has established a series of local community advisory panels to provide input to the policies and practices of companies operating chemical sites in their localities. By early 1996, according to the results of a PIACA national survey, there were 30 such panels operating around Australia (an increase of 50 per cent from 1993). Forty companies (40 per cent of PIACA's membership) were actively involved in communicating face to face with their local communities at panel meetings, which took place at varying frequencies from four to 11 times a year.⁽⁹⁴⁾ Survey responses from community members indicated that the majority were moderately to well satisfied with the progress. The two most commonly expressed suggestions were for industry to advertise/promote the process of forming local advisory panels, and to actively encourage community members to give their scarce time to this important activity. Such local activities continue to be overseen by a national community advisory panel.⁽⁹⁵⁾

New training courses and material have been developed. In the United States, as part of the implementation of the Chemical Manufacturers' Association's (CMA) Community Awareness and Emergency Response (CAER) Code, a new employee training programme, Chemfacts For Chemical Industry Employees, was developed for employees who said they did not have enough information about their company and the industry to talk with neighbours. The five-part programme covers all aspects of Responsible Care and uses videos, presentations and group exercises to share key information about the chemical industry with employees.⁽⁹⁶⁾

As part of community outreach, new approaches have been developed on issues where industry has been traditionally sensitive or felt itself especially vulnerable to public and media criticism. Following a hydrogen gas explosion at DuPont Canada's Maitland plant in Ontario in 1995, fortunately without casualties, the company moved rapidly to inform the community of events. Within hours of the explosion, the news was released to the media and two teams were visiting neighbours to talk about the incident and to assess damage, although none was reported. Ironically, the Maitland explosion occurred about a month before a scheduled community dialogue event, where the plant's worst-case scenario was to be presented. When DuPont was originally verified, it was criticized for its inadequate community dialogue process and for not having communicated worst-case scenarios at most sites. The community dialogue event occurred subsequently and some 150 people turned up to learn about the plant's worst-case scenario: a vapour cloud which could ignite and explode, and an accidental release of hydrogen fluoride gas.⁽⁹⁷⁾

3.5.2. Education programmes for schools, colleges and universities

Educational programmes and outreach activities have been developed by most trade associations and, in addition, individual companies often have their own schemes. It is clear that in many instances such programmes have been boosted as a result of VIs which are now incorporated into curricula and activities.

The French Chemical Industries Association (UIC) has a comprehensive schools education programme through which its RC initiative is promoted. Chimie la Classe is for pupils from 10 to 11 years old, Olympiades de la Chimie is aimed at grammar school pupils from 16 to 17 years old, whilst the Fédération Guy-Lussac is an association of 17 chemistry and chemical engineering colleges linked with the UIC training department.⁽⁹⁸⁾

The Singapore Chemical Industries' Club's key HSE initiative in 1998 was the launch of an education outreach programme which is targeting over 20,000 12 year-olds. Working with the Singapore Science Centre, the programme is introducing lower secondary school students to the world of chemicals in a series of presentations. A pilot programme of 12 sessions took place from August to September 1997.⁽⁹⁹⁾

The South African Chemical and Allied Industries Association (CAIA) has prepared a Responsible Care "awareness" training course for use by lecturers at technical colleges and universities, designed for chemistry, chemical engineering and environmental health students. The course material consists of manual and overhead transparencies. Lecturers who adopt the course are provided with copies of the management practice standards and encouraged to include Responsible Care in case studies, design projects or assignments. The course can also be used by industry for awareness training.⁽¹⁰⁰⁾

Since 1990, the German Chemical Industry Association (VCI) has held a series of teacher conventions for upper secondary level chemistry and biology teachers. In 1996, 700 teachers came to Frankfurt to attend special lectures and information forums, to visit the information market and to discuss RC. In addition, two weekend seminars for teachers were held for the first time in the state of Hesse under the motto "Responsibility for the future".⁽¹⁰¹⁾

At company level, and as part of Responsible Distribution in the United States, Chautauqua Metal Finishing Supply, Ashville, New York, hosted an awareness day in 1996 about their company. The company invited fourth graders from a local school to learn about chemical distribution by visiting their plant, and set up six teaching stations to explain all aspects of their business; 15 employees spent 2-3 hours on this project.⁽¹⁰²⁾

In 1997, British Petroleum (BP) China signed an agreement with the State Education Commission and the World Wide Fund for Nature (WWF) China (a non-governmental organization) to work on an environmental education project in China entitled the "Environmental Educators' Initiative". Phase I of the project, from October 1996 to March 1997, concentrated on workshops for project development, whilst Phase II, from April 1997 to September 1999, is currently focusing on curriculum and training development. This project is characterized by the joint effort of the State Education Commission, WWF and BP to improve environmental education. The focus of the project will be on environmental educators' training, aiming to develop an environmental education programme which can be incorporated into the school curriculum at the national level. The project will centre on three teacher training institutions, namely Beijing Normal University, East China Normal University and Southwest China Normal University and 24 nearby pilot primary schools, where the material and methodology developed under this project will be tested.⁽¹⁰³⁾ This is the first time in China that a government department, an environmental non-governmental organization and a foreign company have worked together on a shared objective, and each of the parties will provide an input to the project. All are equal partners and are contributing two members each to the steering committee through which the project is managed.

VIs raise the issue of the need for new partnerships between industry and other parties to improve HSE performance through training. One encouraging example is a social partnership to produce training materials to encourage the involvement of German works councils in the RC programme. The GIBUCI is the German partnership for the provision of information to works councils about environmental protection in the chemical industry and was founded in 1987. This instrument was created by the German Employers' Association for the Chemical Industry (Bundesarbeitgebervereband Chemie e.V -- BAVC) and the trade union representing workers in the chemical industry, IG Chemie-Papier-Keramik. It provides works councils with continually updated information to help them deal with matters of environmental protection. One important outcome of the GIBUCI's training activities is a new, large volume of transparencies about Responsible Care and environmental management systems containing background information and training advice. It is designed not just for works councils, employees and foremen but also for management representatives. Developed in close consultation between IG Chemie, BAVC and the VCI, the series was compiled by the Work and Environment Foundation of IG Chemie.⁽¹⁰⁴⁾ Other training activities include: organization of a two-day external environment and safety seminar for works council members at two-year intervals; environmental protection weeks for trainees and apprentices; annual, one-day briefing for senior management staff and works council members on "Legal aspects of environmental protection".⁽¹⁰⁵⁾

Over 60 works agreements in Germany have extended the rights of works councils beyond safety matters to participation in strategic decision-making as it affects the environment.⁽¹⁰⁶⁾

Training and education bodies may be able to play more direct roles in voluntary initiatives. For example, Interfora, based in Lyon, France is a regional chemical industry training body run and financed by the French chemical industry. The institute provides training for the chemicals, pesticides and pharmaceutical manufacturing industries in the Rhône-Alpes region, one of the heartlands of the French chemical industry. It trains newcomers to the industry as well as providing continuous training courses for management, workers and contractors. Interfora's director says that her institute has not been directly involved in RC training as such, but would have the capacity to do so.⁽¹⁰⁷⁾ This statement together with similar evidence from several other countries suggests that in many instances RC is still seen as something external to many parts of the chemical industry and is not yet fully integrated into mainstream industrial training and education.

3.6. Evaluating the impact of VIs on HSE training, education and performance

Measuring the effectiveness of training and education in improving HSE performance is a challenge. As an article in the ILO Encyclopaedia of Occupational Health and Safety notes:

Until very recently the effectiveness of training and education in controlling occupational health and safety hazards was largely a matter of faith rather than systematic evaluation [...] this has begun to change and educators and researchers are applying more rigorous approaches to evaluating the actual impact of worker training and education on outcome variables such as accident, illness and injury rates and on intermediate variables such as the ability of workers to identify, handle and resolve hazards in their workplaces.⁽¹⁰⁸⁾

To isolate the effects of certain types of training -- those attributable to the VIs -- on HSE performance is more difficult still.

To measure progress in all aspects of HSE performance, and to allow comparison between companies and country associations on the basis of standardized data, performance indicators are being developed as part of voluntary programmes. CEFIC, for example, is developing 16 pan-European indicators to measure progress in implementing RC, as already described in Chapter 2. Similarly, the European Association of Chemical Distributors (FECC) as part of its Responsible Distribution/Care initiative is developing a European single assessment document based on 18 precise audit questions to measure progress in HSE performance. When fully developed, such data sets on HSE performance should facilitate more rigorous assessment of the effectiveness of training and education. Pending the availability of such scientific tools, the subjective judgements of informed parties can provide useful material for evaluation purposes. In that spirit the following testimonials from professionals in the industry are offered as indicative of the difference that VIs in general, and their training and education components in particular, have made.

For the HSE Systems Development Manager of the ICI Group, who is also a member of CEFIC's RC Committee, RC has brought only a small added value to HSE performance because ICI's HSE systems in most cases already went beyond the voluntary programme's requirements. For ICI, RC would add value if its communication aspect of publicizing continuous performance achievements could be strengthened. He believes that ICI and other RC companies are not adequately communicating their successes to the public, external decision-makers and even their own employees. However, he acknowledges that RC could be of value in imbuing company personnel with an HSE mentality.⁽¹⁰⁹⁾

The philosophy of RC is reflected in ICI's approach. ICI Polyurethanes, Shepton Mallet (United Kingdom) states that:

All personnel are thoroughly trained in safety, health and environmental (SHE) matters as part of our continuous improvement philosophy. The effectiveness of safety training is shown in our minor accidents measurement where, in 1989, 163 minor accidents were recorded, but in 1995 we recorded only four ... [and] ... Training for all employees is also important in understanding the environmental implications of our work ... [and] ... We take every opportunity to present our excellent SHE performance to all audiences, whether they are employees, customers, the local community, schools, or any other interested groups.⁽¹¹⁰⁾

For BP Chemicals, RC is seen as playing a complementary role to its own HSE programmes. Since 1987, the International Safety Rating System (ISRS) has been used as the worldwide basis for BP Chemicals' own safety and environmental management/audit system. There are external audits every two years. In the United Kingdom, building from ISRS, and incorporating the CIA's RC Management Systems Guidance, BP has now launched its Operation Integrity Assurance System (OIAS) globally across the company. OIAS contains 85 "expectations". These expectations can be called anything on site as long as the objectives and targets can be met and audited. A company spokesperson said, "Most of what is in RC is already in OAIS -- if not, the gaps will be plugged."⁽¹¹¹⁾

In 1988, DuPont adopted RC as a standard for operations in all its facilities worldwide. At that time, it was a company that operated according to its own standards in the areas of employee health and safety, pollution prevention and distribution. Indeed, many of the company's operations staff questioned the need for a CMA regime superimposed on what the company was achieving on its own. DuPont's vice-president of operations, Asia-Pacific, says though that RC has added two things to what the company was already doing:

It gave existing programmes a global framework and a system by which to measure progress and benchmark against other chemical producers; and it heightened community interaction and product stewardship efforts ... [and] ... It has allowed us [DuPont] to create an umbrella [covering] all aspects of the supply chain ... [and] ... It has allowed us to see where the gaps are and fill them in.⁽¹¹²⁾

Union Carbide's vice-president for HSE says that, "The biggest impact [of RC] has been giving us a template and a common mode to carry out efforts in HSE across the board."⁽¹¹³⁾ Employee awareness of the programme reached 99 per cent in 1997. The company carries out safety audits with trained employees in conjunction with external auditors.⁽¹¹⁴⁾

According to the CEO of Eastman Chemical, United States, probably the biggest benefit to come from RC is better communication. He says:

We had an active HSE programme before RC but we weren't communicating it to the public and our employees. More than anything else, RC has taught us that HSE is not just an activity that stays inside the [plant] fence ... [and] ... It extends to more than setting up community advisory panels too. Implementing codes has changed the way we perceive the people we buy from and sell to. RC has forced us to go back and build in product stewardship right from the Research & Development level. We want to deal with responsible suppliers, distributors and customers, and we're ready with help when they need it.⁽¹¹⁵⁾

Hatco, an American synthetic lubricants and biodegradable surfactants manufacturer with 187 employees, views implementing RC as an integral part of competing in the chemical industry. With RC, safety training has been enhanced, with emergency drill teams working closely with local fire department hazardous materials teams and other emergency responders. The company president says: "We're focusing more on planning and prevention, not just emergency handling." As a result, recordable safety incidents dropped by 60 per cent in 1997.⁽¹¹⁶⁾

Whilst German chemical firms have been at the forefront in seeking EMAS registration and ISO accreditation, with the encouragement of the VCI which sees them as complementary to RC, companies have mixed views on the impact of these systems on training and education. The experience of Solvay, Germany, offers an interesting perspective on the relevance of EMAS and ISO to HSE training and education, which is a well established tradition within the company. Responsible Care was introduced in 1991 and is accompanied by regular verbal and written information for all employees. Internal training and education programmes include close cooperation with the works council. A company spokesperson says that:

Activities towards EMAS/ISO 14000 had no significant influence on the training/education activities. Just exactly the other way round: the preceding training/education programmes facilitated the auditing procedures necessary for EMAS/ISO 14000 and led to a high level of acceptance for the extra workload.⁽¹¹⁷⁾

A company spokesperson for Hüls AG made similar observations and pointed out that the potential changes brought about by EMAS and ISO depend very much on the present structure and on the specific development of each of the companies. There is less impact with highly developed management systems, whilst in general it is greater for SMEs. Hüls AG places a high emphasis on well qualified employees in all HSE matters. It is one of the most important goals of the company's environmental programme to maintain a high level of employee education, information and personal responsibility. Given the already highly developed information systems, he felt there was only "a slight additional effect caused by joining EMAS".⁽¹¹⁸⁾

The experience of InfraServ Hoechst, Germany, is different. During the preparation for the validation of EMAS, the company reported that the amount of training and intensive education for all personnel on all aspects of HSE, and especially on EMAS, increased significantly. In particular, the company developed an EMAS learning programme (on CD-ROM) together with the Stiftung Arbeit und Umwelt, as well as a learning programme SIM-ALARM for emergency management response.⁽¹¹⁹⁾

Furthermore, EMAS's impact is extending beyond EU countries. The Association of the Chemical Industry of the Czech Republic (SCHP) participates in an intersectoral working group aimed at incorporating the EU EMAS directive into Czech law. SCHP's HSE director says that ISO, EMAS, and RC are really parts of a general environmental management system package which merge together at plant level, so that it is often impossible to separate the individual elements. ⁽¹²⁰⁾

Training and education for HSE, including awareness raising, is part of a broader chemical industry training scene that has changed considerably in recent years, as was seen at an earlier ILO meeting. Some of the implications of voluntary initiatives for training were identified at that session. Awareness raising and training in communication skills have become increasingly important. Blue-collar workers, for example, now often receive communication training, which allows them to communicate the results of the VI to visiting external auditors/verifiers, who as part of their verification often want to talk directly to employees. Equally, the training provides them with the skills needed to communicate the achievements of VIs to their families, neighbours, fellow citizens and the media beyond the factory gate.

New community/school training and education initiatives have been another central feature of VIs. In the case of RC, many companies have established community advisory panels made up variously of company representatives, local councillors and government officers, community associations and individual community members. There has been a new willingness to invite the community into the chemical plants to see for themselves. Similarly, new training and education activities incorporating the VI element have been developed with school pupils and their teachers, and often with colleges and universities.

Evaluating the HSE training dimension of VIs presents the same kind of difficulties as those involved in assessing the VIs in broader terms. HSE training attributable to VIs is difficult to distinguish from what did or would take place in the absence of VIs. This difficulty is compounded by the practice of many companies, often for good reasons, of not using the logo and name of RC or other voluntary initiatives in their HSE work. Nevertheless, there are many examples from different regions of HSE training activities associated with the VIs. These are carried out by different actors -- chemical manufacturers, trade associations, distributors and suppliers. They are intended for varied audiences -- company managers and white-collar staff, blue-collar workers, contractors, SMEs, communities, decision-makers and the general public. It does appear that the development of the VIs has led to improvements in the quality and quantity of HSE training.

Although rigorous evaluation of the effectiveness of this training in terms of HSE performance is not now possible, considerable "soft" evidence suggests that there have been significant benefits.

Notes

1.  ILO: The implications of structural change for employment and training in the chemical industries, Report II of the ILO Chemical Industries Committee, 11th Session, Geneva, 1995, p. 41.

2.  ibid., p. 40.

3.  ILO: Chemical Industries Committee, 11th Session, Note on the proceedings (Geneva, 1995), p. 38.

4.  G. Paulson et al.: "Environmental education and training -- The state of hazardous materials worker education in the United States", in Encyclopaedia of Occupational Health and Safety (Geneva, ILO, 1997).

5.  Florian Wegleitner: Responsible Care -- ein Vergleich -- der Initiative für Gesundheit, Sicherheit und Umweltschutz in der chemischen Industrie -- zwischen Österreich und England (Vienna, Austrian Chemical Industry Association, 1997), available in German only.

6.  CEFIC: Responsible Care -- A chemical industry commitment to improve performance in health, safety and the environment (Brussels, 1993), p. 7.

7.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 2.

8.  Personal interview on 14 Aug. 1998 with Jim Whiston, Chair of CEFIC's RC Committee.

9.  Site visit plus personal interview on 14 Apr. 1998 with Frank Richardson, Chief Chemist, and other staff, Thomas Swan & Co. Ltd., Consett, United Kingdom.

10.  Personal interview on 16 June 1998 with Catherine Lequime, RC Coordinator, UIC, Paris.

11.  PACIA: Responsible Care report 1997 (Melbourne, 1997), p. 3.

12.  ibid.

13.  Facsimile from Mr. Motoo Kawamata dated 21 July 1998.

14.  ILO: The implications of structural change for employment and training in the chemical industries, op. cit., p. 43.

15.  CCPA: Responsible Care report 1995 -- A total commitment (Toronto, 1996).

16.  CIA: Responsible Care -- Responsible neighbours (London, 1993), p. 31.

17.  Personal communication dated 18 June 1998 from Liz Anderson, RC Manager, CAIA, South Africa.

18.  ibid.

19.  "Down to the wire -- Responsible Care code goals near", in Chemical Week (United States, 2-9 July 1997), p. 29.

20.  Personal communication dated 3 June 1998 from Dan Roczniak, RC Manager, CMA, Arlington, United States.

21.  Personal communication (undated) from E. von der Meer, RC Manager, VNCI,The Hague, the Netherlands.

22.  Careline: Focus on contractor safety (London, 1998), Issue No. 10, p. 14.

23.  Central Committee of Experts SCC: Safety checklist contractors,version 1997/01 (Leidchendam, the Netherlands, 1997).

24.  Personal interview on 15 Apr. 1998 with Linda MacCleod and Laurie Barry, BP Chemicals, Saltend, United Kingdom.

25.  Barry S. Dyer: Responsible Care -- Managing the health and safety of contractors (Address to Asia-Pacific RC Conference, 1998).

26.  Personal interview on 15 Apr. 1998 with Linda MacCleod and Laurie Barry, BP Chemicals, Saltend, United Kingdom.

27.  Personal interview on 15 Apr. 1998 with Chris Beckett, HSE Adviser, BP Chemicals, London.

28.  Personal communication dated 20 June 1998 from Mr. Aimo Kastinen, Director, KT, Helsinki, Finland.

29.  Canadian Chemical Producers' Association: Responsible Care report 1996 (Ottawa, 1997), p. 10.

30.  ibid., p. 4.

31.  "Small firms grow with big firm help", in Chemical Week (1-8 July 1998), p. 101.

32.  "Setting a healthy standard", in Chemical Week (1-8 July 1998), p. 89.

33.  Personal communication dated 20 May 1998 from Frauke Druckrey, RC Manager, VCI, Frankfurt, Germany.

34.  1998 Asia-Pacific Responsible Care report (Tapei, TCRA, 1998).

35.  CEFIC: 1998 Responsible Care Workshop (Brussels, 1998), Draft proceedings, Foreword.

36.  "Product stewardship takes center stage", in Chemical Week (1-8 July 1998), p. 116.

37.  Personal interview on 16 June 1998 with Catherine Lequime, RC Coordinator, IUC, Paris.

38.  CAIA: Personal communication from Liz Anderson, RC Manager, 18 June 1998.

39.  KT: Responsible Care progress report 1996 (Helsinki, 1997), p. 7.

40.  Personal communication dated 20 June 1998 from Mr. Aimo Kastinen, Director, KT, Helsinki, Finland.

41.  Kemikontoret: The Swedish chemical industry and Responsible Care -- Progress report 1990-94 (Stockholm, 1996), p. 3.

42.  ibid., p. 5.

43.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 26.

44.  Personal communication dated 15 July 1998 from Sverre A. Hostmark, PIL, Norway.

45.  Japan Chemical Industry Association: Activity report on the Responsible Care programme in Japan (RC Asia-Pacific-Conference, Taiwan, 1998), p. 3.

46.  JRCC: Responsible Care 1996 annual report (Tokyo, 1997), p. 30.

47.  Personal communication dated 21 July 1998 from Motoo Kawamata, Deputy General Manager, JRCC, Japan.

48.  ibid.

49.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 27.

50.  Personal communication dated 19 June 1998 from Silvia Surova, RC Manager, ZCHFP, Slovak Republic.

51.  ZCHPF/VUP: Responsible Care report 1997 (Bratislava, 1998).

52.  Personal communication dated 10 July 1998 from Jacques Busson, RC Manager, CEFIC, Brussels.

53.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 13.

54.  CIA: Responsible Care cell network (London, July 1997).

55.  ibid.

56.  Personal communication dated 30 June 1998 from Stuart Aaron, RC Manager, CIA, London.

57.  ILO: Responsible Care in India -- Voluntary initiatives on education and training, by the People's Science Institute, Dehradun, India (Geneva, 1998), p. 15.

58.  ibid.

59.  ibid.

60.  ILO: Responsible Care in the chemical industry in India (Geneva, 1998), pp. 11-13.

61.  Personal communication dated 4 July 1998 from M.H. Bae, Korea Petrochemical Association, Seoul, Republic of Korea.

62.  Dr. Jim Whiston, ICCA: Keynote address (Asia-Pacific RC Conference, Tapei, 1998).

63.  Emma Chynoweth: Draft report of Asia-Pacific RC Conference 1998 (Taipei, 1998), unpublished.

64.  ibid.

65.  Tsai Hsung-Hsiung, Taiwan Responsible Care Association: Keynote speech (Asia-Pacific RC Conference, Taipei, 1998) p. 1.

66.  ibid.

67.  ibid.

68.  Chemical Industries Club of Thailand: Responsible Care status report, May 1998 (Asia-Pacific RC Conference, Taipei, 1998), p. 1.

69.  "Mexico faces unique challenges", in Chemical Week (1-8 July 1998), p. 109.

70.  ILO: Environmental management initiatives by the Chilean chemical industry (Geneva, 1998), Status Report, p. 7.

71.  Personal communication dated 1 June 1998 from Mike Moss, ICI Groups Systems SHE Development Manager, Middlesborough, United Kingdom.

72.  Emma Chynoweth: Draft report on Asia-Pacific RC Conference (London, 1998), unpublished.

73.  Personal communication dated 3 June 1998 from Dan Roczniak, RC Coordinator, CMA, Arlington, United States.

74.  VCI: Responsible Care report 1997 (Frankfurt, 1997), p. 14.

75.  "Meeting the product stewardship challenge", in Chemical Week (1-8 July 1998), pp. 80-81.

76.  Personal communication dated 3 June 1998 from Dan Roczniak, RC Coordinator, CMA, Arlington, United States.

77.  "Meeting the product stewardship challenge", in Chemical Week, op. cit.

78.  ibid.

79.  ibid.

80.  ibid.

81.  ibid.

82.  "Europe begins to measure performance", in Chemical Week (1-8 July 1998), p. 111.

83.  "Product stewardship takes center stage", in Chemical Week (1-8 July 1998), p. 116.

84.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 11.

85.  VCI: Responsible Care report 1997 (Frankfurt, 1998), p. 33.

86.  CIA: UK indicators of performance 1990-97 (London, 1998), p. 28.

87.  ibid., p. 30.

88.  CEFIC: Annual Responsible Care report 1997 (Brussels, 1998), p. 31.

89.  Personal communication dated 8 June 1998 from Inge Lundstrom, RC Manager, Kemikontoret, Stockholm, Sweden.

90.  Personal communication dated 3 June 1998 from Dan Roczniak, RC Coordinator, CMA, Arlington, United States.

91.  CEFIC: Annual Responsible Care report 1997, op. cit., p. 13.

92.  Site visit plus personal interview on 14 Apr. 1998 with Frank Richardson, Chief Chemist, and other staff, Thomas Swan & Co. Ltd., Consett, United Kingdom.

93.  Personal interview dated 15 Apr. 1998 with Jim Whiston, Chair of CEFIC's RC Committee.

94.  PACIA: Local community advisory panels continue to grow in Australia (Melbourne, Feb. 1996), Media release.

95.  ibid.

96.  CMA: Responsible Care progress report 1997 (Arlington,, United States, 1998) p. 2.

97.  Canadian Chemical Producers' Association: Responsible Care report 1996 (Ottawa, 1997), p. 6.

98.  Personal interview dated 16 June 1998 with Catherine Lequime, RC Coordinator, UIC, Paris.

99.  "Singapore -- Companies in the classroom", in Careline (London, Oct. 1997), Issue No. 9, p. 6.

100.  Personal communication dated 18 June 1998 from Liz Anderson, RC Manager, CAIA, South Africa.

101.  VCI: Personal communication from Frauke Druckrey, RC Manager, 20 May 1998.

102.  NACD Chemical Education Foundation: Community outreach, ideas and examples 1996-97 (Washington, DC, 1997).

103.  Personal communication dated 13 Jan. 1998 from Mr. Michael Zhao, BP China.

104.  10 years of successful employer-employee partnership in protecting environment (Wiesbaden, GIBUCI, 1997), press release.

105.  Involvement of employees and works council beyond the provisions of the Industrial Constitution Law (Düsseldorf, Henkel KGaA, undated).

106.  "Globalization will hamper sustainability, say trade unions", in Careline (Apr.-June 1998), Issue No. 11.

107.  Personal interview on 24 Apr. 1998 with Martine Dumont, Director, and Rémy Perret, Development Consultant, Interfora, St. Fons, Lyon, France.

108.  T.H. McQuiston et al.: "Evaluating health and safety training -- A case study in chemical workers' hazardous waste worker education", in Encyclopaedia of Occupational Health and Safety (Geneva, ILO, 1997).

109.  Telephone interview on 7 May 1998 with Mike Moss, ICI Group HSE Systems Development Manager.

110.  ICI Polyurethanes: Responsible Care at Shepton Mallet -- Excerpt from site presentation (Shepton Mallet, undated).

111.  Personal interview on 16 Apr. 1998 with Geoff Chalfont, Chris Beckett et al., BP Chemicals, London.

112.  "An industry takes its bearings", in Chemical Week (1-8 July 1998), p. 85.

113.  ibid.

114.  ibid.

115.  ibid.

116.  "Tough chemistry, safe operations" in Chemical Week (1-8 July 1998), p. 104.

117.  Personal communication dated 29 July 1998 from Michael Ruhland, Solvay, Germany.

118.  Personal communication dated 29 July 1998 from Thomas Gohring, Hüls AG-KSU, Germany.

119.  Personal communication dated 29 July 1998 from Dr. Mathilde, InfraServ Hoechst, Germany.

120.  Personal interview on 4 Feb. 1998 with Mr. Ivan Zika, SCHP RC Coordinator, Prague, Czech Republic.

4. Summary and points for discussion

For several reasons, voluntary initiatives are becoming more important as means of promoting good health, safety and environment performance in various industries; chemical manufacturing has been a lead sector in this regard. Although this approach does not eliminate a role for government regulation, it does tend to be accompanied by a shift away from "command-and-control" towards goal-setting types of regulation. Although not precisely defined, the term "voluntary initiatives" is taken here to comprise company and industry-wide initiatives, government-industry environmental agreements, and environmental (or HSE) management systems. Environmental agreements -- that is, bilateral agreements between industry and government -- have been widely developed in Western Europe and have been used for some purposes in the United States. Standards for environmental management systems form another significant class of voluntary initiatives. The main examples are EMAS in the European Union and the ISO 14000 standard. Increasing numbers of firms and sites are being certified under one or both of these schemes. Corporate HSE reports represent still another kind of voluntary initiative that is gaining in importance. Although there are identifiable differences between these voluntary initiatives, there is considerable scope to integrate them at company and plant level so as to minimize confusion in the perception of the work force and the general public.

The main voluntary initiative sponsored by chemical industry associations is Responsible Care, but this is supplemented by more focused initiatives dealing with specific segments of the industry. These include Responsible Distribution, Coatings Care, and the Global Safe Use Initiative of the pesticides industry. The other initiatives are intended to be compatible with RC while taking account of the special features of the subsectors involved. The Global Safe Use Initiative is largely devoted to training activities.

Responsible Care has been adopted by some 40 national chemical manufacturers' associations, whose members account for well over half of world chemical output. Historically, it has spread from the more highly industrialized to the less industrialized countries. Its structure -- built around a set of general principles, accompanied by a number of codes or guidance documents detailing how they should be applied -- is similar for all participating national chemical associations, but details of the programme vary from country to country.

Assessing the impact and effectiveness of VIs in improving HSE performance is not straightforward. In some instances, this is because the initiatives are too recent for proper evaluation, as in the case of CC, and to some degree, EMAS and ISO. With RC there is more information, though performance indicators have not been uniformly developed by all trade associations, and company self assessment and/or third-party verification schemes are of recent introduction or have yet to be introduced. Even where self-assessment and third-party verification schemes exist, the degree of disclosure of information to workers and the public varies. With the pesticide Global Safe Use Initiative there are industry-generated data on progress but no third-party data or performance indicators.

Notwithstanding these reservations, there seems to be evidence that VIs have had positive impacts in terms of improving company HSE performance on an industry-wide basis -- impacts that are reaching SMEs as well as large MNCs, developing as well as developed countries. For example, although the evidence is mixed, there is some reason to believe that the development of voluntary initiatives such as Responsible Care has led the general public in some countries to take a less negative view of the chemical industries. The application of VIs, and especially RC, has led chemical manufacturing enterprises to take increasing account of the views of a wider range of stakeholders. These include local communities near the plants, interest groups and the general public. They also include other parties along the supply chain -- suppliers, clients, distributors and users. As a result of VIs, CEOs of chemical enterprises appear to have become more committed to good HSE performance. The concept of product stewardship, which is an important part of RC in a number of key countries, embodies the principle that manufacturers should take a life-cycle approach to the HSE effects of their products. Propagating this view has brought increasing involvement of business and financial managers in HSE issues. All of this may add up to a significant change in the culture of the industry.

In some instances, the VI approach has also stimulated new dialogue and ways of interacting between companies in the same sector who often saw themselves as competitors rather than bodies with common problems and interests. The RC "cell" programme is one example of this new type of inter-company dialogue. The VI approach has also stimulated cooperation and, in some cases, partnerships between different sectors of the chemical industry, emphasizing the interdependence of the various sectors, and the fact that a bad reputation for one can mean a bad reputation for all. All the industry-initiated programmes stress their compatibilities and equivalencies, and in many cases formal partnership arrangements have been signed.

Set against these positive achievements of the VIs are several issues that do not appear to have been fully resolved and which can be expected to get more attention in the future. Principal among these are the following:

(i) Low employee and public recognition of industry-initiated VIs, especially in the case of RC. In many companies and countries this is due to the fact that the RC terminology and logo are not used in HSE training and education and in communications within and outside the plants. This dichotomy between what the industry as a whole is projecting as its flagship VI and the language/logo used at employee and community level is an issue which the industry may want to address if it wishes to raise levels of worker motivation and external recognition for its efforts. Workers and their organizations have generally not been directly involved in the initiative and in many cases wish to be more closely associated with it.

(ii) Proliferation of VIs which -- in view of their differences in terminology, logo, and reporting requirements -- can be a problem. In practice RC, EMAS and ISO often merge into one general HSE management system at plant level, and it becomes difficult to identify the precise impact of a particular VI in raising company performance. How far management systems for safety and health should be integrated with those for environment -- and how both should be integrated into general training programmes -- will probably continue to require attention.

(iii) Monitoring and evaluation: some companies and national trade associations are choosing company self-assessment as the main method. Others are moving towards third-party verification. How much and in what way these results should be communicated to the workforce and public are also likely to remain issues. The number of auditors/verifiers to be trained will probably increase significantly.

Training and education for HSE, including awareness raising, is part of a broader chemical industry training scene that has changed considerably in recent years, as was reviewed at an earlier ILO meeting. Some of the implications of voluntary initiatives for training were identified at that session. Awareness raising and training in communication skills have become increasingly important. Blue-collar workers, for example, often now receive communication training, which allows them to communicate the results of the VI to visiting external auditors/verifiers who as part of their verification often want to talk directly to employees. Equally, the training provides them with the skills needed to communicate the achievements of VIs to their families, neighbours, fellow citizens and the media beyond the factory gate.

New community/school training and education initiatives have been another central feature of VIs. In the case of RC, many companies have established community advisory panels made up variously of company representatives, local councillors and government officers, community associations and individual community members. There has been a new willingness to invite the community into the chemical plants to see for themselves. Similarly, new training/education activities incorporating the VI element have been developed with schools, and often with colleges and universities.

Evaluating the HSE training dimension of VIs presents the same kind of difficulties as those involved in assessing the VIs in broader terms. HSE training attributable to VIs is difficult to distinguish from what did or would take place in the absence of VIs. This difficulty is compounded by the practice of many companies, often for good reasons, of not using the logo and name of RC or other voluntary initiatives in their HSE work. Nevertheless, there are many examples from different regions of HSE training activities associated with the VIs. These are carried out by different actors -- chemical manufacturers, trade associations, distributors and suppliers. They are intended for varied audiences -- company managers and white-collar staff, blue-collar workers, contractors, SMEs, communities, decision-makers and the general public. It does appear that the development of the VIs has led to improvements in the quality and quantity of HSE training.

Although rigorous evaluation of the effectiveness of this training in terms of HSE performance is not now possible, considerable "soft" evidence suggests that there have been significant benefits.

Suggested points for discussion

In the light of the foregoing treatment of the issues, the following list of points is offered as a basis for the meeting's discussions:

1. What are the respective strengths and weaknesses of voluntary initiatives and government regulation for assuring socially and environmentally responsible performance by the chemical industries? What combination of the two approaches is most likely to lead to high levels of HSE performance?
2. Do voluntary initiatives such as Responsible Care effectively contribute to spreading best HSE practice and, if so, how?
3. When companies commit themselves to Responsible Care or other voluntary initiatives, what changes should be made and what does that commitment entail in terms of the level and type of HSE training and education carried out?
4. What is best practice in training and education on voluntary initiatives to improve HSE performance?
5. What are the education and training needs and priorities associated with widening the coverage of VIs in SMEs and developing countries? How can such needs best be met?
6. What information and training do workers and their representatives need in HSE in relation to voluntary initiatives, including Responsible Care? What role should they play in determining such information and training needs?
7. How can and should the effectiveness of voluntary initiatives in general, and associated training efforts in particular, in promoting better HSE performance be measured and tracked?
8. To what extent should and can chemical industry workers be associated more closely with voluntary initiatives? What benefits, e.g. in terms of motivation and credibility, would this bring? What role might "voluntary agreements" between employers and workers and their representatives play in this regard?
9. What training and education efforts are needed to promote the concept of product stewardship and, more broadly, a life cycle view of the HSE impact of the chemical industries?
10. What can the ILO do to contribute to improvements in HSE performance through voluntary initiatives and associated training and education activities?

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