| by Debra C. Phillips
The American Chemistry Council, an Arlington, Virginia-based trade association, represents leading chemical producers in the United States. The council's more than 120 members represent about 90 percent of U.S. chemical production capacity. Although the ACC is largely an advocacy organization, it cares deeply about its members' performance on issues relating to environmental protection, employee and product safety, safe production and transport of chemicals, emergency preparedness, and community outreach. Clearly, excellent environmental health and safety performance is a worthy goal on its own. However, the ACC extracts additional value from its program; that is, if ACC members perform well in these areas, advocacy for ACC members on a variety of issues becomes more effective and compelling.
The ACC has implemented a program called Responsible Care to promote continuous improvement of environmental, health, safety and security (EHSS) issues for all its members. First conceived in 1984 by the Canadian Chemical Producer's Association (CCPA), Responsible Care was seen as a way to improve performance as well as respond to public concerns. Building on a set of guiding principles developed during the 1970s, the CCPA introduced the program to its members in 1986. The ACC, recognizing the value of this comprehensive approach, adopted the initiative on Oct. 31, 1988, as an obligation of membership. That day marked a turning point at the ACC (known then as the Chemical Manufacturers Association) by raising the bar for performance expectations of a trade association and its members.
Throughout the 1980s and 1990s, Responsible Care at the ACC was largely based on codes of management practices. A total of six codes identified best practices that ACC members were expected to assess themselves against, and then report findings and progress to the ACC. The codes included employee health and safety, process safety, product stewardship, distribution, community awareness and emergency response, and pollution prevention. In the 1990s a voluntary peer-review process called management systems verification (MSV) was added to the program, and more than 60 percent of ACC members participated.
In 2002, the ACC's board of directors adopted sweeping and ambitious changes to Responsible Care in the United States. After nearly 15 years of code implementation and voluntary MSV participation, ACC leadership made significant changes to the program for several reasons:
• U.S. regulation of the chemical industry had caught up with Responsible Care requirements. By 2002, only 25 percent of Responsible Care went beyond regulatory requirements, as opposed to 87 percent in 1988.
• Performance under Responsible Care had leveled off in some areas.
• A lack of alignment existed between Responsible Care and company business processes and objectives.
• Stakeholder recognition and support for the program was minimal, leading to calls for independent oversight.
The certification debate Changing Responsible Care was hotly debated within the ACC's membership, and discussions on third-party certification were among the most intense for several reasons. First, the ACC is just one of 52 national associations with members implementing Responsible Care. The ACC would be the first participative trade association of its type to adopt a third-party management systems certification. Second, concerns arose that a systems approach could chip away at the heart and soul of Responsible Care, creating a more robotic process focused on paperwork rather than ethics. Third, some argued that systems approaches haven't demonstrably delivered improved performance. Fourth, the U.S. chemical industry was in a period of economic downturn, and changes would be costly in terms of systems implementation as well as auditing. Finally, the last thing any company was looking for was another audit.
Despite these concerns, a majority of members believed that a systems approach paired with third-party certification would deliver performance improvement, level program requirements, move the program beyond government mandates, and align Responsible Care more closely with leading business processes and customer requirements.
An enhanced and revitalized Responsible Care program was unveiled in 2002, comprising the following core components for each ACC member and its U.S. operations:
• An integrated management systems approach, incorporating all aspects of Responsible Care
• Mandatory third-party certification at the headquarters and facility levels to demonstrate conformance either to the Responsible Care Management System or the RC14001 technical specification
• Required performance reporting to the ACC, which includes posting individual and aggregated industry data to the association's Web site at www.responsiblecare-us.com
The schedule for certification completion and sample scheme for facilities is provided in figure 1 below.
Once these changes to Responsible Care were adopted at the ACC, significant work was required to make the new certification requirement operable. Two distinct management system models were developed based on member-company feedback. The first, RCMS, is a plan-do-check-act model that incorporates all the traditional EHSS requirements of Responsible Care as well as new security elements adopted in the wake of Sept. 11, 2001.
The second model, RC14001, uses ISO 14001 as a foundation and adds Responsible Care elements to broaden its scope beyond environmental issues. Procedure documents were written to establish auditor credentials and training requirements, as well as audit service provider (ASP) oversight. The ACC sought and executed agreements with the ANSI-ASQ National Accreditation Board (ANAB); the Board of Environmental, Health and Safety Auditor Certifications (BEAC); and RABQSA to provide oversight and credentialing services. The process to become a training organization for Responsible Care management system audits, an approved auditor or an ASP is open. To date, more than a dozen ASPs have been approved to conduct Responsible Care certification audits, and three organizations have developed approved auditor training courses.
Many questions have been raised during the past several years about the RC14001 technical specification, its relationship with ISO 14001 and the reason ACC pursued it. A variety of factors led to the development of RC14001.
First, it's important to note that prior to the ACC's decision to make management certification a mandatory component of its Responsible Care program, some members were already seeking a process to align their industry requirements under Responsible Care with customer requirements to demonstrate conformance to ISO 14001. Because of the worldwide recognition of ISO 14001, particularly in Europe, and its resulting popularity with stakeholders, companies sought an approach that would avoid duplicative Responsible Care and ISO 14001 audit processes. The RC14001 technical specification was designed to embody the elements of both programs, thereby allowing a single certification process to fulfill both program requirements.
Work toward expanding ISO 14001 beyond environmental issues to cover all Responsible Care components was completed in 2001 by an ACC member workgroup with significant ISO 14001 experience. In RC14001, the scope of ISO 14001 is extended to include "Responsible Care and health, safety and security" at each reference to "environment" within the ISO 14001 standard. To obtain RC14001 certification, organizations must conform to the ISO 14001 environmental management system requirements as well as the other disciplines included in the expanded scope.
Along with the general expansion of the ISO 14001 scope, RC14001 includes an additional 27 requirements.
In its policy section, RC14001 requires a demonstration of personal commitment from top management, open communications with stakeholders and a commitment to the guiding principles of Responsible Care.
In aspect identification and assessment of effects, RC14001 spells out a requirement to consider transportation risk, security vulnerability, risks from products and processes, and managing product and process information.
There's a clear "outside the fence line" focus in RC14001, which gets to the heart of Responsible Care: taking responsibility for your products and operations throughout the chemical supply chain.
RC14001's implementation and operation section contains many additions to ISO 14001 and focuses particularly on fully including stakeholders in the EHSS management system. Specific requirements include:
• Employee performance programs that recognize excellent EHSS performance
• Systems to communicate with stakeholders--including employees--and to assess their concerns
• Training programs for business partners and emergency response organizations to ensure appropriate flow of hazard and risk information during normal operations and emergencies
In the specification's checking section, additional requirements are added to the analysis of a company's EHSS and its business partners' performance trends as well as to incident investigation leading to corrective and preventive action.
In late 2001, RC14001 was piloted and deemed acceptable by the ACC and ANAB (then known as the Register Accreditation Board).
ACC members have risen to the challenge of management systems certification. More than 50 companies' headquarters and an estimated 100 facilities have been certified to date. Most companies have been certified against the RCMS technical specification at their headquarters, while an equal number of RCMS and RC14001 certifications have taken place at the facility level. An additional 50 certifications of headquarters combined with facility operations at small companies are expected by the end of 2006. The ACC anticipates approximately 300 facility certifications by the end of 2007.
In general, companies are reporting positive experiences with the certification process. Companies that are new to systems approaches have experienced better organization and turnover management, improved purchasing and vendor controls, integration of multiple audit processes, formalization of procedures, and a shift in focus from the person to the function. Companies with greater management system experience have found it easy to expand from ISO 14001 and ISO 9001, and have used existing surveillance audits to complete RC14001 certification. Other companies have successfully integrated their ISO 9001, ISO 14001 and RC14001 audit processes. All companies have reported that
headquarters-level management systems have been exceedingly useful in ensuring the effectiveness of the management system organizationwide.
Responsible Care is now practiced in 52 countries worldwide. Each country's program is managed by its leading trade association. Globally, Responsible Care is managed by the International Council of Chemical Associations and is governed by the Responsible Care Global Charter, which sets a global vision for the Responsible Care program.
The ACC RCMS certification process is available to any ACC member or Responsible Care partner worldwide. Because of its link to ISO 14001, RC14001 certification is available to any organization, provided an accredited registrar is used for the audit. Several ACC members seeking to implement and certify their global management system are opting to carry out RCMS and RC14001 certification audits worldwide. Audits have occurred or are scheduled at locations in China, the Netherlands, Ireland, Wales and South Africa.
The American Chemistry Council in Arlington, Virginia, represents more than 100 of the leading companies engaged in the business of chemistry. All ACC members implement Responsible Care, a management system-based program that requires public performance reporting as well as third-party certification of company management systems. In her capacity as managing director of Responsible Care, Debra C. Phillips manages all aspects of the ACC Responsible Care program and staff. She also leads the international Responsible Care Leadership Group, which sets and carries out the programmatic direction of the global Responsible Care initiative within its 52 participating countries. Responsible Care, the hands logo mark, RC14001, Responsible Care Management System and RCMS are registered service marks of the American Chemistry Council.
|
