Appendix 11

Distribution incident reporting guidelines

1. Background

Under its Responsible Care initiative, the chemical industry is committed to continuously improve the Health, Safety and Environmental performance of its distribution activities whereby the prevention of incidents is highly important.

Internal incident reporting of distribution incidents is already common practice in many chemical companies and offers individual companies a solid basis for carrying out risk assessments and taking remedial actions. Lack of common reporting criteria however makes it difficult to demonstrate performance improvements to the public in a comprehensive way.

2. Objective

These Guidelines intend to stimulate individual chemical companies to continue or to start collecting distribution incident data according to the proposed common definitions and criteria. This approach will lead to consistent reporting by individual companies, by national chemical federations at national level and eventually by CEFIC at European level, facilitating consistency with reporting by Authorities.

Although individual companies should continue to investigate causes for incidents individually, this approach will contribute to an improved exchange of information and will lead to a continuous reduction of chemical distribution incidents.

3. Definitions and criteria

3.1. Definitions

Distribution:

The "in-transit" transport (air – rail – road – sea – inland waterway – pipeline) of chemicals between the site of a supplying chemical company and that of the final customer

• including the transport and off-site loading/unloading at ports, airports, warehouses etc.
• excluding the transport and loading/unloading activities at the premises of the supplying chemical company and the final customer.

Chemicals:

• All chemicals "owned" by the reporting chemical company. This includes not only finished products, but also samples, raw materials, intermediates, wastes etc.
• All products of the chemical industry, whether or not classified as hazardous according to the UN Recommendations for the Transport of Dangerous Goods

3.2. Qualifying criteria

Although companies should obviously consider all distribution incidents (and near-misses), these Guidelines consider only distribution incidents meeting at least one of the following criteria:

• Death - Injury
  Death or injury, leading to an absence from work of at least 3 days, of a person involved in the distribution incident irrespective of whether or not the chemical contributed to the death and/or injury.
• Spill - Leak
  Any spill/leak of > 200 kg for hazardous chemicals or > 1000 kg for non-hazardous chemicals
  (Hazard classification according to the UN Recommendations for the Transport of Dangerous Goods):
• Property Damage
  Any damage, greater than 40,000 XEU, to property of any party resulting from the distribution incident including any cost of decontamination and/or clean-up irrespective of whether or not the chemical contributed to the property damage.
• Public Disruption
  Any public disruption, lasting more than 1 hour, caused by the danger or perceived danger of a chemical distribution incident resulting in road closures, restriction of activities, evacuation of public or any other precautionary measure impacting the public. The intervention of emergency services automatically qualifies the incident as a distribution incident
• Media Coverage
  Any incident that results in adverse national media coverage.

4. Collection and reporting process

4.1 Data to be collected

Incident data should be collected by transport mode, split by bulk (tanks, tank containers) and packaged (can, drum, bag, IBC etc.). In order to enable future aggregation of data, also the tonnage linked to each transport mode should be collected.
See 4.4 for suggested format of data collection.

4.2 Reporting

The following reporting process is proposed whereby the first step will take effect immediately, the second step will be initiated by the different national chemical federations and the third step will be started by CEFIC.

Step 1: Each shipping point of a chemical company collects the incident data as suggested in 4.4 for all transport originating from this shipping point. For future reporting to national chemical federations these data should be split per country where the incident occurred.
Step 2: Each chemical company reports the above data to the respective national chemical federations of the countries where an incident occurred.
Step 3: The national chemical federations report the incident data and volumes, aggregated at national level, to CEFIC, at least once a year.

4.3 Indicators of performance

Future reporting by national chemical federations and CEFIC (see Steps 2 and 3) will result in publishing the following indicators of performance by aggregating data from individual chemical companies and national chemical federations respectively:

• number of incidents (per transport mode)
• number of incidents/tonne (per transport mode)

4.4 Suggested format for data collection