by Daniel Roczniak

Today's rapidly changing business environment confronts managers with a complex set of internal and external stakeholder demands. Senior management is seeking increased efficiencies and cost savings to remain competitive in the global marketplace while maintaining a safe workplace. At the same time, an organization's customers seek assurance that it can meet exacting standards for quality; avoid disruptions due to economic, environmental, health, safety and, more recently, security factors; and lower costs through more efficient production and better management of the supply chain. In addition to these important business drivers, managers must continue to respond to the public's environmental, health, safety and security (EHSS) performance expectations for the organization's manufacturing activities, as well as its products, as they move from production to final use and disposal.

The American Chemistry Council's member companies and Responsible Care partners developed the RC14001 technical specification as a tool to better integrate EHSS activities within their business operations while also meeting commercial and other stakeholder demands for improved performance. RC14001 uses the ISO 14001 environmental management system (EMS) standard as a platform, adding health and safety and security issues to the management system's scope. RC14001 also includes specific Responsible Care elements related to transportation and supply chain management, product stewardship and stakeholder engagement, all of which require managers to consider hazard and risk issues well beyond their organization's physical boundaries.

Organizations that have conducted RC14001 audits report improvements in the following areas: employee training and awareness, purchasing controls for EHSS service providers and vendors, integration of EHSS goals and objective-setting processes, contractor qualification and selection, integrating internal auditing procedures, and coordination and management of the EHSS-related activities (e.g., sales, marketing, research and development, commercial partner selection, security, etc.) traditionally "owned" at the corporate or business- division level.

Background: ACC and Responsible Care
The American Chemistry Council (www .americanchemistry.com) is the nation's largest trade association representing the business of chemistry. ACC's 130 member companies and their 880,000 employees represent about 85 percent of the total chemical production volume in the United States. These organizations manufacture thousands of products that are essential to our modern way of life.

Responsible Care, the industry's EHSS performance-improvement initiative, was adopted by ACC as an obligation of membership in 1988. In 1992, ACC expanded the initiative's reach by creating a partnership program for organizations such as barge, rail, warehouse, bulk-liquid terminal storage and trucking companies, all of which handle chemicals in the supply chain. The Responsible Care partner program now includes more than 80 companies ranging from class one railroads to logistics management companies.

Responsible Care is centered on key requirements that are intended to improve the overall performance of the industry, respond to stakeholder concerns regarding the industry's operations and its products, and assist companies in improving their overall business operations. These key Responsible Care requirements include annual reporting of specific EHSS performance data on a publicly available Web site (www.responsiblecare-us.com); adhering to a set of guiding principles that establish the framework for EHSS activities; implementing a security code that requires enhancements of physical (i.e., site) security, cyber security and security of products in the supply chain; and certifying Responsible Care management systems through a third-party audit process.

RC14001 was developed as one option for Responsible Care third-party certification for ACC members and partners in 2002. Member companies requested that a process be developed to allow them to meet customer demands for ISO 14001 while also meeting their ACC Responsible Care certification requirements. Successful completion of the audit results in two certificates, one for ISO 14001 and one for RC14001. A second option for certification, known as RCMS, was developed for use by companies that want to meet their ACC certification requirements, but have no need for ISO 14001 certification. Like RC14001, RCMS is a classic policy-plan-do-check-act management system model, but is focused specifically on Responsible Care elements and doesn't include certain requirements found in ISO 14001 and RC14001. RC14001 is available to any organization regardless of its business profile, provided its audit meets ACC certification requirements. (See www.rctoolkit.com for information on the Responsible Care initiative and its key requirements.)

RC14001: building a better management system
The initial question asked by individuals unfamiliar with the Responsible Care certification process concerns the differences between RC14001 and ISO 14001. There are a number of significant differences, beginning with the expanded scope of the audit. RC14001 follows ISO 14001's outline in its entirety, and companies seeking RC14001 certification must demonstrate conformance to ISO 14001 to successfully gain their RC14001 certificate. However, wherever the word "environment" appears in the ISO 14001 text, companies implementing RC14001 are required to add "Responsible Care health, safety and security" to the scope of the activity. The environmental policy now becomes an environment, health, safety and security policy or, better yet, a Responsible Care policy. Aspects and impacts, goals and objectives, and timetables now include a wider range of activities, including health and safety factors as well as security issues.

By expanding the scope of the management system, organizations have the opportunity to take a holistic view of their operations and products and to include multiple management disciplines in the system's development and implementation. As management silos are breached, the organization can begin to take advantage of cross-functional expertise and the more efficient use of pooled resources. RC14001 provides organizations with the opportunity to integrate their processes and procedures in planning, training, compliance monitoring, corrective action and measurement, record keeping, document control and management review. A number of ACC companies are integrating their quality systems with RC14001 to create a truly seamless business operation.

In addition to expanding the scope of the existing ISO 14001 elements, RC14001 includes 27 new requirements in the management system. These additional requirements focus on activities that the chemical industry and other business sectors have historically viewed as critical to the success of Responsible Care (or EHSS for non-ACC companies), including maintaining up-to-date risk information on products and processes, assessing transportation-routing risk for products, recognizing employee EHSS excellence, engaging in proactive outreach and dialogue with stakeholders, participating in industry mutual assistance activities, qualifying commercial partners based on EHSS performance, measuring the EHSS performance of commercial partners, determining if customers can safely handle products, and assessing security vulnerabilities. In many cases, interactions with commercial partners aren't managed at the plant level, so an organization seeking RC14001 certification may be required to include headquarters and/or business unit personnel in the audit process. This can be an eye-opening process for departments and individuals who may have viewed themselves as immune from previous EHSS audits.

RC14001 and the supply chain
The chemical industry, like other sectors, is subject to market forces that require the efficient delivery of product to its customers. In the matter of chemical products, efficient delivery also means getting the product to the customer safely and with minimal disruption due to accidents or worker injuries. Selection of the correct carriers, toll manufacturers, storage facilities and logistics providers to support product movement to customers is a critical piece of the chemical business. Likewise, chemical companies are equally concerned about the ability of customers (and often their customers' customers) to handle their products safely. For more than 15 years, ACC members have worked closely with their commercial partners to steward products through the supply chain, sharing the industry's experience, knowledge and resources to eliminate any possibility that chemicals might be mishandled or otherwise misused.

RC14001 includes a number of requirements that focus on the industry's supply chain concerns and require specific product-stewardship actions, including reviewing EHSS performance when selecting a commercial partner (e.g., carriers, contractors, toll manufacturers, suppliers, etc.), reviewing commercial partners' ongoing performance on a periodic basis, and sharing risk information and working with commercial partners (including customers) to ensure safe handling of products. ACC members have learned that robust interactions on EHSS issues can help solidify existing supply chain relationships, lead to increased business opportunities and spread the Responsible Care ethic to others. RC14001 reinforces these requirements and opportunities.

A new dimension: security
Following the attacks of Sept. 11, 2001, ACC's member companies quickly closed ranks and moved to further strengthen the security of chemical operations and the chemical supply chain. Although the industry had always been concerned about the security of its operations, it was a traditional focus aimed at maintaining safe working conditions and operations, preventing acts of retaliation by disgruntled employees, or preventing theft of product and/or proprietary information. In 2002, ACC adopted a mandatory security code for its members and Responsible Care partners that required assessments of security vulnerabilities and implementation of countermeasures at company sites, within information technology/cyberstructure and along the supply chain. The code was written in a plan-do-check-act format so it could be incorporated into the RC14001 (and RCMS) management system model.

Organizations seeking RC14001 certification are required to make security an integral part of their management systems. As a result, security issues can be found among company aspects and impacts, employees are receiving security training, countermeasures are being implemented by organizations at their locations and in concert with their commercial partners along the supply chain, and security has become part of the internal checking, corrective action and management review processes. RC14001 certification and its continuing surveillance audits will continue to ensure that robust security programs are part of company management systems.

Ensuring credibility
In creating its Responsible Care certification process, ACC determined that it was necessary to develop a process that met the high expectations of its membership and the industry's stakeholders. Registrars seeking to conduct RC14001 audits must first be accredited to conduct ISO 14001 audits and then must conduct an additional witness audit for RC14001. RC14001 witness audits are conducted under the supervision of the ANSI-ASQ National Accreditation Board (www.anab.org) using established processes. As part of its commitment to continuous improvement, ACC is also working with registrars to identify common trends being reported on RC14001 certification audits so it can assist its members in improving their management systems and performance.

Individual auditors must meet ACC expe rience and qualification requirements to ensure that they have sufficient knowledge and expertise. ACC also requires auditors to attend and pass accredited Responsible Care auditor courses that provide comprehensive instruction on the initiative and its requirements, including new security issues. Finally, each auditor participating in the process is required to be certified by RABQSA International (www.rabqsa.com) or the Board of Environment, Health and Safety Auditor Certifications (www.beac.org). Auditor certification requirements include passing a Responsible Care test administered by BEAC.

In an effort to reach out to local stakeholders and make RC14001 more transparent, ACC has strongly encouraged its members to include the local public in their auditing process. To date, several ACC companies have invited local residents to attend all or part of their RC14001 audit as observers. In several cases, auditors have requested and been given access to local chemical company-sponsored community advisory panels (CAPs) so that they could gather evidence on the organization's implementation of outreach requirements found in the RC14001. ACC members are also sharing the results of their audits with local stakeholders as another example of meeting public expectations for transparency.

Conclusion
The RC14001 technical specification is providing ACC member companies, Responsible Care partners and a growing number of companies outside the chemical industry with a powerful tool to drive performance improvement and integrate their management systems. Although still a relative newcomer to the list of established management systems models, RC14001 has attracted widespread interest from companies in the oil and gas, automotive supply, mining, and other business sectors both in the United States and overseas. By giving companies the opportunity to conduct a single audit covering a comprehensive set of requirements, business managers can respond to multiple internal and external stakeholder expectations while minimizing the need for competing management systems models.

About the author
Daniel Roczniak is the director of Responsible Care implementation
and performance at the American Chemistry Council in Arlington, Virginia, where he manages ACC's Responsible Care certification and mutual assistance programs. QD