Responsible Care - 14001:2013 and RCMS:2013 Standard Revisions

RC-14001 and RCMS Standards, the chemical industry’s environmental, health, safety, and security performance initiative (originally released in 2002) recently underwent a revision to a 2013 re-release. The revision incorporates changes based upon issues identified by members, partners, registrars, and board recommendations on waste and energy efficiency. Additionally, the task force working on the revision ensured that any changes would provide value and would align with the American Chemistry Council’s Process Safety Codes. The program revisions address the principle to enhance the performance and credibility of the chemical industry through Responsible Care.

What follows is a brief summary of changes to the RCMS and RC-14001 Standard.

RCMS® Responsible Care Management System
Element 1.1 now includes a requirement for the policy to be made available to the public.

Element 2.1, which initially required the site to identify hazards and prioritize risks, now requires organizations to consider NEW items – including activities associated with its operational energy efficiency and waste minimization, reuse and recycling. Sites are not necessarily required to have energy or waste prioritized risk aspects; they just have to show they considered them.

Element 3.4 adds the requirement that sites verify competency for persons performing tasks directly related to the organizations prioritized EHSS risks.

Element 3.5.2 states that – in addition to having a process for making product stewardship information publicly available – process shall now include product safety information.

Element 4.2 now requires the organization to periodically evaluate its compliance with relevant health, safety, security and environmental legislation and regulations, as well as conformance with other Responsible Care®-related requirements to which it subscribes.

Element 4.3 adds the requirement that an organization conduct internal audits on the effectiveness of its Responsible Care management system to determine whether it has been properly established, implemented and maintained. Additionally, audits shall occur at planned intervals with audit frequency commensurate with risks associated with the operations, results of previous audits, and changes to the management system.

Element 4.4 states that (commensurate with risk) the organization shall have a process to use (as appropriate) that reviews and assesses: customers, suppliers, contract manufacturers, carriers, distributors, contractors, and third-party logistics providers based on Responsible Care or other health, safety, security and environmental performance criteria established by the organization.

Element 4.6 previously required root cause analysis of incidents, accidents. and non-conformities within Management System and now is modified and split into two sub-elements:

• 4.6.1 – Identify, investigate and assign significance
• 4.6.2 - Based on the determined level of significance…
  
  
  • Identify root causes
  • Address and mitigate any adverse impacts
  • Initiate and complete corrective and preventive actions
  • Share key findings and associated corrective and preventive actions with relevant internal and external stakeholders, and
  • Review efficacy of corrective and preventive actions taken

Element 5.1 adds the new requirement: outputs from the management review shall include any decisions and actions related to possible changes to the policy, goals, objectives and targets, and other elements of the Responsible Care management system.

Other modifications include an updated glossary and terms appendix, a listing of current ACC member/partner company requirements, and updated web links for ACC documents.

RC-14001 – Responsible Care Management System plus ISO-14001: 2007

Section 4.3.1 Aspects and Impacts identification now includes some additional wording that requires the organization to consider operational energy efficiency, waste minimization, as well as reuse and recycling when identifying its aspects and impacts.

Section 4.4.6 Operational Control includes a wording change to sub-element “h” to ensure that an organization has a process to use, as appropriate, that reviews and assesses the following: customers, suppliers, contract manufacturers, carriers, distributors, contractors, and third-party logistics providers based on Responsible Care or other health, safety, security and environmental performance criteria established by the organization.

Section 4.5.3 Non-conformity, corrective, preventive action changes the language of incident and accident investigation to ensure that the organization has “A process to identify, investigate cause(s) and assign significance to incidents and accidents. Appropriate corrective and/or preventive action(s) shall be taken to avoid recurrence.”