| < Previous |  |
Next > |
|
Employees are essential
stakeholders in Responsible Care. However some surveys reveal that, at least in some
countries, many employees and their representatives are unaware of Responsible Care and do
not feel involved. The explanation for this is that Responsible Care is a value-based initiative. The ICCA’s objective for Responsible Care is to improve the behaviour of the whole industry. To achieve this purpose we need to develop Responsible Care into management activities, practices and guidance which means design and publish codes, guidance or checklists. |
Invariably chemical companies have integrated these management practices and activities into their own style of management systems, often with their own branding. These systems are detailed to specific company needs and often more comprehensive than the Responsible Care requirements because the company systems also incorporate legal and cultural aspects and other needs such as reporting lines and organisation charts which are important to the company and which are not necessarily covered by Responsible Care. As a result, the Responsible Care management practices may lose their individual identity in company integrated management systems.
In consequence, we don’t always tell our employees enough. Over the years there have been many new initiatives: first it was total quality management, then quality assurance, then it’s Responsible Care and now ISO 14001. Employees are often involved in Responsible Care activities without actually being aware of the generic and collective context of the voluntary initiative.
| Many employees and their representatives are unaware of Responsible Care and do not feel involved |
This is an explanation, this is not a justification: we do believe that we need our employees to know more about and to understand better Responsible Care. We must be able to explain how companies’ HS&E programmes meet their Responsible Care commitments.
| We must thus have more "Responsible Care awareness actions" at local level directed towards our employees and their representatives. This must be addressed by initiatives taken at national level according to national regulations and local customs and must include both a top down information process and a bottom up involvement process of our employees and their representatives. |
|
Assessment of the implementation of the Responsible Care initiative at site and company level calls for checking that the Responsible Care fundamental features, guiding principles and associated codes of practice or guidance have been implemented, with practice in place to sustain continuous improvement.
It is this practice which will provide the HS&E performance improvement and the communication strategies that Responsible Care is seeking to deliver. The methods by which implementation and performance is judged range from internal self-assessment processes to third party verification. Some of the different approaches to verification by four different federations are reviewed below.
The fundamental features of Responsible Care have been developed by CEFIC into a "Comprehensive Menu of Requirements". These requirements form the basis of a HS&E management system, which CEFIC strongly promotes as a way of delivering continual HS&E performance improvement. Though Responsible Care is much more than a management system, it is this system which is CEFIC’s starting point for both self-assessment and verification processes.
Agreement was reached in 1998 to adopt the following approach: the national federations ensure that the core requirements defined in the CEFIC menu are incorporated into national codes and guidance. Federations have either already developed, or are engaged in developing, self-assessment questionnaires which incorporates the CEFIC core set as a minimum.
Companies or sites will complete the self-assessment questionnaires according to the national federations protocol at least every three years, and the federations will collate the self-assessment feedback. The results will be published, used to benchmark companies’ implementation progress and to prioritise where companies or federations require assistance.
The environmental standards EMAS and ISO 14001 can play a useful part in implementing part of the Responsible Care requirements.
For this reason, the CEFIC menu makes many cross-references to these two standards.
A peer review process which can include people external to the industry, from local communities or other Responsible Care advisory panels is the route chosen by CMA in the United States with its Management Systems Verification: MSV.
MSV is a process for evaluating evidence of a companies management system for practising Responsible Care by trained industry verifiers from other companies and members from the general public.
In the United States, approximately 50 companies have completed a Responsible Care Management Systems Verification. Another 75 companies have committed to complete verification during the next two years. Members of the public from communities hosting chemical facilities are active participants in the verification process. The verification is intended as a tool to assist companies in improving their overall Responsible Care implementation and to sustain effective environment, health and safety systems. One result of the verification process is the compilation of company "examples of excellence" for use by the industry in improving its overall performance.
In Canada the verification process is required once a member company CEO has attested that the company has completed their three-year Responsible Care implementation process.
It involves a three-day visit to every CCPA member company by a team comprised of two industry experts, an activist (usually from the CCPA national advisory panel) an a citizen selected by each visited site community.
The team interviews management, workers, neighbours, customers, carriers and others, as well as reviewing documentation, to verify that the company has indeed implemented all codes of practice and instilled the Responsible Care ethic. It produces a consensus report on whether or not the company has indeed fully implemented Responsible Care, and if not, it schedules repeat visits until such confirmation is achieved. The company makes the findings available to its employees, communities, peers and any other interested parties.
Other than the newest member companies, all but two companies have been visited and these are scheduled for early 1999. Seven visited companies are in the process of completing outstanding items needed for team sign-off.
Of the 1500 findings of verification teams to date, about half have been commendations for excellent management systems and activities, especially in the areas of pollution prevention, CEO leadership and risk assessment. The other half were either suggestions for improvement or areas requiring follow-up by the team, usually involving employee awareness and community dialogue, and in particular communication of worst case scenarios and other risks to plant communities.
| A consensus report is produced on whether or not the company has indeed fully implemented Responsible Care |
CCPA is now field testing a second round of the verification process which will be undertaken on the third anniversary of a company’s successful completion of its first verification.
It is designed to:
In Australia in 1994, some five years after the initial adoption of the Responsible Care commitment, it was decided that the credibility of the initiative would be significantly enhanced by a program of independent external verification of internal company self-assessments of progress towards implementing the various Codes of Practice.
| Available information will be compiled and if necessary supplemented by further testing |
A formal verification protocol was developed and three firms of independent auditors were selected and provided with training on the Codes. A company site and relevant code is selected by PACIA and the site asked to nominate one of the auditing firms (usually the firm already involved in the auditing of that site for Quality System Accreditation to the ISO 9000 series). Sites are encouraged to include as observers in the verification team members of the local community or government authorities. Typically, verifiers audit some 30-50% of the individual code management practices from the selected site’s self-assessment return.
|
Since verification
audits commenced in 1995 some 104 sites/code self-assessments have been verified. Results
indicate that over 91% of management practice self-assessments are confirmed as accurate
or thought to be understated. The National Community Advisory Panel has commented
favourably on the success of the verification program but continues to encourage greater
involvement of local community members in the verification teams. PACIA and companies with 65% of chemicals and plastic emissions have signed greenhouse challenge agreements with the Australian Government to reduce emissions by 10 to 20% by 2003. |
Responsible Care does not stand still. In response to issues raised at community, national or global level, ICCA members are constantly reviewing their policies and activities in the light of the guiding principles. In response to both the endocrine issue and the challenge of High Production Volume chemicals, ICCA responded to these issues in a way that was consistent with Responsible Care. ICCA is also working on the climate change issue with the same determination. Our aim is to develop a balanced response that maintains our focus on reducing harmful effects while addressing the need for economic development and improved energy efficiency. A selection of recent voluntary initiatives undertaken by ICCA members is reported below.
The public’s low level of trust in the chemical sector - despite many efforts to raise performance and help improve public knowledge of and confidence in the industry - continues to be a major concern.
But an ICCA commitment made in 1998 under the banner of Responsible Care may well, in time, make a real difference. The industry has promised to develop a more thorough process for chemicals assessment and management in consultation with governments and other stakeholders in order to achieve a higher level of public confidence in the process for the safe management of all chemicals. Industry intends to do this by developing an effective program of public communication and stakeholder dialogue. The initiative is based on practical processes for improved data collection, risk assessment and risk management of those existing chemicals agreed by all parties to constitute a risk to health.
In Germany, self commitments are a political tool, which are playing an increasingly important role in environmental policy. The VCI has initiated about 30 self commitments since the 1980’s. They comprise ambitious goals which can be better achieved with this flexible tool than with regulatory standards. However, voluntary does not mean arbitrary, and the need for a state regulatory framework for environmental, consumer and health protection is not called into question. Two examples of these VCI self commitments are given below.
A self commitment has been made to establish a minimum data set for all chemicals with quantities of more than 1,000 kg per annum, including intermediates, until the year 2002. Within the next five years VCI member companies will internally record and document the chemicals handled in their operations. Available information on such chemicals, which are relevant to safety and environmental protection, will be compiled and if necessary supplemented by further testing.
Organizational measures will be taken to ensure that companies can provide information on the listed substances at any time should there be a need to do so. As long as gaps in their knowledge persist, they should proceed on realistic worst case assumptions. VCI will report annually on the progress achieved in these activities and encourage VCI member companies to allow competent public authorities at any time access to their compiled substance documentation. Furthermore VCI is offering to act as a co-ordinator for the participating companies with a view to burden sharing.
Together with the German Construction Chemicals Manufacturers and the Paint Makers Association VCI submitted a self commitment on wood preservatives to the Federal Ministry of the Environment at the beginning of 1998, containing the following pledges:
The Federal Minister of the Environment has expressly welcomed the VCI action, which is also backed by the wholesale, foreign and retail trade.
The Occupational Safety and Health Administration (OSHA) has initiated the Voluntary Protection Program (VPP) enabling companies with comprehensive, successful occupational safety and health programs to receive OSHA "Star" certification. "Star" certification entitles companies to receive fewer routine scheduled inspections.
The VPP concept recognizes that compliance enforcement alone can never achieve the objectives set forth in regulatory guidance, and that comprehensive, successful safety management programs which go beyond OSHA standards can protect workers more effectively than programs aiming simply to achieve compliance. The VPP program has resulted in numerous forums for mutual assistance and sharing of effective safety and health practices and programs.
| Performance data will reflect the national progress and achievements of the chemical industry |
The Environmental Protection Agency (EPA) "Green Lights" Program is one of a number of US government programs in which private sector entities can participate with the objective of improving energy efficiency and reusing CO2 emissions. "Green Lights" achieves this objective by facilitating the installation of energy efficient lighting. Participants agree to survey their facilities, install energy efficient lighting where economically justified and complete this process within five years. EPA provides technical support. "Green Lights" has recently been incorporated into a broader program, "Energy Star Buildings" which aims to achieve the same objective using a variety of approaches in addition to energy efficient lighting. A number of SMA companies participate in "Green Lights" and other voluntary government programs.
An Energy Efficiency agreement signed in the UK in November 1997 has achieved 2 important Responsible Care goals; the Association has made a public commitment to an energy efficiency target for the year 2005, significant in the post Kyoto world, and it has encouraged a busy exchange of best practice by networking the Government-funded consultancy support given to selected member companies.
In recent years the need to publish quantitative information on HSE performance has been an increasingly important priority facing the industry. Companies and federations responded to this call at an early stage. For example, the European Chemical Industry issued "Guidelines on Environmental Reporting" in 1993 in order to promote the publication of annual reports by its members. These guidelines were well received and many companies and federations have since published environmental reports at different levels - local, national, European and international.
In addition, many chemical industry federations now publish Responsible Care indicators of performance. These take the form of aggregated HS&E performance data from their countries’ members and reflect the national progress and achievements of the chemical industry.
But the selected indicators still vary both from company to company and from country to country according to national or local concerns and parameter definitions. In order to communicate continuous HS&E improvement at national, European and global level, the chemical industry needs a more comprehensive and quantitative assessment of its HS&E performance based upon common definitions.
In November 1998 CEFIC published its new "
CEFIC Responsible Care HS&E Reporting Guidelines". These guidelines will enable the future aggregation of data at European level, since all member federations will adhere to 15 common core parameters and their definitions, whilst providing a basis for a company to publish data at site or company level. The choice of core parameters on which to collect data was dictated by the need to satisfy two key requirements: they had to incorporate the HS&E data which operating sites are already collecting for a number of reasons and they had to take into account our stakeholders’ expectations.All companies and federations are encouraged to develop their own reporting strategy, taking into account these basic set of core parameters in their Responsible Care reports. Additional parameters reflecting national or local concerns can be added to this core set. Through this approach there should be a convergence of publications by chemical industry companies and federations thus enhancing accountability.
| All companies and federations are encouraged to develop their own reporting strategy |
In order to publish a global picture of the sector’s HS&E performance and performance improvement, the Responsible Care Leadership Group is addressing ways of collating comparable national data. This would enable ICCA to monitor continual improvement and to benchmark performance, and help to identify areas in need of collective support and additional guidance. Such transfer of sector best practice is a fundamental objective of Responsible Care.
