Sunday 11 November 2012

Responsible Care as an Example of Chemical Industry Movement to Achieve and Demonstrate Improvement in Safety, Health and Environmental Management and Performance


Responsible Care as an Example of Chemical Industry Movement to Achieve and Demonstrate Improvement in Safety, Health and Environmental Management and Performance

by Ms. Veronique Garny

1 What is responsible Care?

The global chemical industry plays an important role in modern society by contributing to the solution of many human problems: hunger, sickness, sanitation, clothing, housing, transportation, leisure. With 6 billion people on earth, a strong and innovative chemical industry is a condition to sustainable development. However the chemical industry, like any other human activity suffers from time to time of accidents in its plants and during its products transportation, some health problems because of product exposure, problems of waste disposal, air and water pollution, bioaccumulation.
How to get the benefits of the the products while minimizing risk of accidents? Responsible Care is the answer of the industry.
Responsible Care is the commitment by chemical companies to demonstrate continuous improvement of environmental, health and safety performance of their operations and products in a manner which is responsive to the concerns of the public.
Communication is an essential component of Responsible Care. It must address all constituencies which are or might be involved in our operations or with our products. That is our customers and what we call our stakeholders: our suppliers and contractors, local communities, authorities and regulating bodies, the general public and of course our employees.
Communication processes must be both ways so that besides explaining what we do, customers and stakeholders can voice their opinions and concerns. It's these communication processes which should enable this industry to improve its perception by the public and maintain its  license to operate  . As a US Telecommunication company CEO stated early in this century:  All business in a democracy begins with public permission and exists by public approval  . The chemical industry is very well aware of that.
Responsible Care is a chemical industry voluntary initiative. It covers all the industry activities from research, process and product development through manufacturing and sales. It aims at an ethical and behavioral change: going away from a regulatory driven approach to a proactive approach taking into account the perceived needs of society all along the product life, from cradle to grave. This approach is much more efficient and demanding because, contrary to  end of pipe regulations  it calls for improvements at all stages of the product cycle . It's more flexible, more comprehensive and to some extent easier to implement since it is designed by the industry for the industry. It encompasses commitments to communication and experience sharing that would be very difficult to organise through regulation.
Responsible Care is a global, I mean worldwide, initiative. In each country there's an association of chemical companies: the national federation. While companies have their own Responsible Care programmes, it's the federation responsibility to adapt the Responsible Care initiative to the cultural, social and legal environment of the country
In Europe, 21 national federations participate in a Responsible Care Committee, inside CEFIC, the European Chemical Industry Council. CEFIC itself is a member of ICCA, the International Council of Chemicals Associations. There's inside ICCA a  Responsible Care Leadership Group  whose prime responsibility is to promote Responsible Care while insuring that Responsible Care implementation in various countries is in accordance with its key elements and fundamental features, thus protecting worldwide the integrity of the initiative.

2 Where and when it came from and how it spread across the world?
Responsible Care started in Canada in 1984. It sprang over to the USA in 1988, then to Western Europe in 1989-1990 and then to the rest of the world. Today, Responsible Care is being implemented in about 40 countries:
21 European countries, including Turkey, none in the former Soviet Union.
In North America: Canada, USA, Mexico.
In South America: Argentina, Chile, Brazil, Colombia, Peru.
In Africa: South Africa, Zimbabwe.
In Pacific/Asia: Australia, New Zealand, Philippines, Japan, India, Taïwan, Hong-Kong, Malaysia, Singapore

3.1 What are the key elements of Responsible Care ?

The involvement and support of a company's Chief Executive Officer or the most senior management person operating in the country is critical to the establishment of overall responsible care ethic within an organization.
Thus the first requirement for a company to be recognised as a participating member in the Responsible Care initiative and its first fundamental feature is the signature by its CEO of guiding principles.These principles are broad statements defining the fundamental ethical responsibilities and operational philosophies of the company, consistent with Responsible Care.
At this time it is not required that all fundamental features of Responsible Care, as described later, are fully implemented for a company to be recognised as following the Responsible Care approach. However the company must present an acceptable implementation plan of these features.
It's chemical companies which manufacture, sell, distribute chemical products. All the field action is at company level : Responsible Care implementation builds on companies' programmes.
The national federation role is to promote the initiative so that most chemical companies inside the country join Responsible Care. National federation also check that the guiding principles are consistent with Responsible Care and that the fundamental features implementation plan is credible. The national federations monitor their members progress, help sharing experience, edit local codes, guidelines, guidance documents and may set minimum requirements.The national federations own and protect the Responsible Care title and logo which signal that Responsible Care implementation meets participation requirements.Thus Responsible Care implementation is a joint effort of companies and federations.

3.2 What are the fundamental features of Responsible Care ?

The fundamental features that companies participating in the initiative are committed to implement are:
A formal commitment on behalf of each company to a set of guiding principles signed by the CEO that I already mentioned.

A series of codes, guidance books, check lists that I will describe next.

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 inside and outside the industry.
Provision of fora 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 the concepts of Responsible Care.
Considerations of how best to encourage all federation members companies to commit and participate in Responsible Care.
Systematic procedures to verify the implementation of Responsible Care by the member companies.

3. 3 Codes, Guidance, Check lists
Community awareness
Emergency response
Pollution prevention
Process safety
Distribution
Employee health and safety
Product Stewardship
Management systems verification

I would like to develop feature NE2 because codes, guidance notes, check lists are tools to turn ethics and guiding principles into practical action.The extent and development of these codes is very different from country to country, depending on local conditions and when the federation started implementing the initiative.As an example, I'm displaying the titles of the codes in the United States. As implementation of Responsible Care progresses, we expect all areas covered by the US codes to be also covered, one way or another in other countries.The Community Awareness and Emergency Response code (for historical reasons it's only 1 code in the USA) adresses relationship and communications between plants and local communities: what are the plant activities, the plant hazards and risks, how are these risks mitigated, how would emergencies be dealt with, especially if there was an incident with consequences outside the plant boundaries.
The titles of the next 4 codes are self explanatory.
Product Stewardship is Responsible Care applied to products: how to ensure that they are designed with due consideration to their potential environmental effects throughout their lifecycle and also how to ensure that they will be handled, used, disposed of safely all along what we call the supply chain from producer to final user and disposal.
Management systems verification was recently added in response to stakeholders concerns about the credibility of the Responsible Care Initiative. It checks that codes implementation is supported by some kind of Deming's wheel management system: Plan (define organisation, provide ressources, set targets and schedule to meet objectives), Do (implement), Check (monitor, review), Act (improve policy and objectives).

4 What is the current status of Responsible Care ?

Like codes, programmes are at very different stages, depending on countries and when the Responsible Care initiative was started.
A few countries already developed and implemented all their codes while achieving significant results.
Accidents reduction: the chemical industry is in most countries amongst those with the lowest fatalities and lost time accidents rates for its personnel.
We also achieved significant waste and effluent reduction. As an example, in Canada under Responsible Care, members companies from the Canadian Chemical Producers'Association have since 1992 reduced their aggregate emissions of all pollutants to water by 99.2 % (140 000 tonnes down to 1 100 tonnes), largely through the conversion of former wastes such as sulfuric acid to saleable products such as gypsum.
We have also published details on many initiatives on improving safety of chemicals transportation and distribution and shared a lot of experience through workshops and seminars and much more.
For countries with a few years of experience with Responsible Care, there are two areas of communication which are already working well. One is communication with local communities through local citizen advisory panels and we see locally that public interest is shifting from plant safety which is of less concern to product safety. By the way, CEFIC is organising a workshop on Product Stewardship in Lyon, next April, to encourage more business people to engage in Product Stewardship programmes.A second area is environmental reporting: most major chemical companies now publish local and global environmental reports, sometimes certified by external auditors, displaying their commitment to Responsible Care and supplying a lot of datas on health, safety and environment to demonstrate their continual improvement.
Collecting aggregate performance data is complex at ICCA level or even in Europe, at CEFIC level because of different definitions.We are presently working on that and our plans for Europe call for publication of aggregated performance data on 16 core parameters, implemented from now till year 2000. These core parameters are listed on next slide. Now that programme development is significant in many countries, we must better assess our progress and demonstrate that we have real programmes and not paper programmes, in other words we must improve verification. First step of verification is self assessment. We, at CEFIC are presently developing a Self Assessment Questionnaire on Responsible Care implementation. The US CMA (Chemicals Manufacturers Association) recently added a Management System Verification code. This verification requires people external to the company, including the local community, to be included in the plants auditing teams.Next step for CEFIC to consider is third party auditing. Some countries are already there like Austria. They claim to have a third party verification system consistent with ISO 9000, ISO 14000, and EMAS (the European Eco Management and Audit Scheme) in place.
At the ICCA Responsible Care Leadership group, we review annually a progress report which each industry federation sends to us on their programme. We are preparing more and more detailed questionnaires to help assess that real progress is made. An ICCA  Responsible Care Status Report  was published last year for the first time. It describes Responsible Care implementation status in 40 countries. This is it and I will be pleased to provide a copy to those of you who are interested.
At European level, CEFIC has been publishing a Responsible Care status report for 3 years now. Again, I will be glad to forward it to those interested.

European Core Performance parameters
1997 Lost Time Accidents & fatalities
1998 SOx, NOx to air
P, N, COD to water
Energy
1999 Hazardous waste
CO2, VOCs
Heavy metals
Distribution accidents
2000 Occupational illness
Non hazardous waste
Selected substances


Many companies are already reporting all these parameters and much more. Our problem is to get agreement in definitions so that we can aggregate data and report as federations or association of federations. There are discrepancies even on what could be seen as simple data such as Lost Time Accident Rate. They are sometimes reported for 200 000 hours, sometimes in number of occurrences per workers. A lost time accident is 3 days absence from work in some countries, 1 day in others, work related illness may be included and so on. Obviously we need more time before we can publish aggregate data on more complex issues like occupational illness or selected substances emissions.

5 Concerns

Just a PR exercise ?
With its communication and experience sharing, the Responsible Care initiative is much more than a Public Relation exercise although we of course highly value an improved public opinion about our industry.
Nothing more than regulations ?
It's also much more ambitious than just meeting regulations as it aims at an ethical, behavioural and cultural change inside the industry.
No performance improvement ?
Achievements and performances improvement which companies report and which we will try to aggregate at CEFIC and ICCA levels in the previously mentioned status reports, are evidence of real, significant performance improvements although we are not yet able to aggregate data.
No public perception improvement ?
We do have some evidence of improvement of public perception, but this improvement is seen close to plants which have local citizen advisory panels. Surveys show that the general public still has a poor perception of the chemical industry.
No stakeholder involvement ?
We have been busy a long time developing codes, agreeing on initiatives.
We must now live up to our commitment to improve the relationship with all our stakeholders which obviously include our workers and their organisations.
A lot of Responsible Care implementation work is actually done by big companies who have experienced and knowledgeable people to do it and then this experience can be shared with SMEs mainly through national federations.
We already do have action in developing countries. For instance the industry is participating in the UNEP-IFCS (United Nations - Environmental Protection and Intergovernmental Forum on Chemical Safety) seminars throughout the world on POPs (Persistent Organic Pollutants) awareness raising and there are many training programmes on the use of agricultural products.
We are willing to extend our Responsible Care activities, using multinational companies as a network while taking into account local sensitivities.

6 Conclusions
Genuine effort
Not perfect, improving
Increased stakeholders involvement
Networking : SMEs, developing countries
Verification

Let me remind you some of the characteristics of the chemical industry:
the long span of time needed to develop a new product and get the authorisation to put it on the market, the huge capital investments needed to build new plants.
These require that we get and maintain that  license to operate  for long periods of time without trouble.
This industry is also very complex and innovative and must attract some of the best brains of each generation, which will be difficult if we don't improve our image.
The success of the Responsible Care initiative is thus vital to this industry. Implementing it effectively and efficiently through genuine efforts doesn't require a police force nor Billy Grahams: it is essentially  enlightened self interest  and companies are increasingly seeing the logic in this apprach.
R.C. means Responsible Care but also Real Commitment.
We still have have to improve our relationships with stakeholders and better listen to their concerns, while providing them better and more transparent performance reporting.
We need to improve the initiative credibility by improving verification processes.
We believe that Responsible Care is a proven, effective means of achieving superior environmental, health and safety performance.
I hope my presentation helped you understand better the importance of this voluntary industry initiative to complement, and, where appropriate, replace regulation and thereby protect human health and the environment.

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