Raising the Bar on Performance

Applauding Responsible Care's overachievers

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And Nexen has a very strong commitment to the TransCAER (Transportation Community Awareness Emergency Response) initiative ," a voluntary outreach effort that helps communities prepare for a potential hazardous material transportation incident. Its involvement in both Canada and the United States dates back to 1986. The company has a division TransCAER coordinator, as well as a designated TransCAER coordinator in each plant. It also participates in at least two TransCAER workshops and two TransCAER training drills each year.

CCPA has honored Nexen with several awards based on the company's achievements under Responsible Care and TransCAER, and ACC recently presented the company with a National Achievement Award for its TransCAER accomplishments.

Litchfield believes that partnering with carriers has been extremely important to the company's success under this code.

"We actually have a formal process that has rewards, report cards, and multitudes of quality and safety meetings that go on during the year at various sites with our carriers," he says. "We reduced our carriers overall ," that's rail, truck and marine, because we ship by all three modes ," from over 100 to approximately 30, and seven of those 30 are partners. So they are people that we deal with first.

"They're the ones, first of all, that are heavily committed to Responsible Care. They can't be a partner without being involved in Responsible Care," he continues. "Number two, they worked with us on our three key areas ," safety, customer service and continuous improvement." All of the company's partners also are leaders in TransCAER, Litchfield emphasizes.

Considering product consequences

Intended to build health, safety and environmental protection into the design, manufacture, marketing, distribution, use and ultimate disposal of products, the Product Stewardship Code is perhaps the most difficult of the codes to truly carry out. At least two companies are doing an admirable job in this area, however.

Like its parent company DowChemical, Indianapolis-based Dow Agrosciences incorporates Responsible Care and environmental health and safety into everything it does, says Shannon Bass, the company's EH&S global product leader. And this attitude is reflected in the company's product stewardship efforts.

"I feel that we're a leader in that we've got a track record that speaks for itself with [our] reduced-risk pesticide registrations and a number of our products receiving the Presidential Green Chemistry Award," says Bass. "That energizes us and provides good examples to people outside our company of the types of things we're capable of."

Dow Agroscience's product stewardship mission, says Bass, is to make environmental health and safety protection an integral part of the whole design and manufacturing, marketing, use and disposal of its products.

"So we kind of say the cradle-to-grave look at the product life cycle is what our whole product stewardship approach encompasses," says Bass. "Product stewardship is heavily integrated into various milestones in the new product development. It's probably six to 10 years before [a product] actually gets launched. There's a lot of opportunity to review and possibly disqualify that candidate based on environmental fate properties or toxicity properties," she adds.

Every three years, Dow Agrosciences examines every single one of its molecules, notes Bass. "Even if nothing major has changed with the molecule, we're going to bring it before a high-level review board here and just talk about all the aspects of the molecule and what, if any, activities we need to continue doing or to incorporate into the product stewardship plan for that molecule."

Millennium Chemicals of Hunt Valley, Md., took a rather unique approach to implementing the Product Stewardship Code: The company appointed its senior vice president of sales and marketing "global code steward" for product stewardship.

John Day, the company's vice president of safety, health and environmental affairs, says Millennium believes it is essential to get the role out into the line organization, pushing the commitment through the organization.

"All of our code stewards are out in the line organization," Day emphasizes. "A pitfall that some companies fall into [is] having the code stewards in the corporate safety, health and environmental group." EH&S personnel also are very involved in Millennium's Responsible Care effort, however.

Millennium also has a product stewardship implementation team for each of its five businesses, notes Day. "You must ," for this particular code ," get the businesses engaged," he maintains.

To enhance code efforts, Millennium has developed a risk assessment process it will be using to assess the sustainability of all its new products. See Fig. 2.

Figure 2. Risk Assessment Flowchart


"We will be systematically looking at our existing products through that process as well as we go forward," says Day. "Basically, you start with what you know about the product and what you don't know. And then you decide from what you don't know what kinds of further testing you need to do on that product so you don't have any blank spaces when you introduce it. Also, you have to do quite a bit of thinking about the end use. What is the product going to be used for, and how can it possibly get misused?"

In addition ," in a move that marks somewhat of an overlap between the Distribution Code and the Product Stewardship Code ," Millennium recently partnered with two other companies to develop a transportation emergency response system for some of its more highly hazardous materials, says Day. The company also has been recognized by ACC for its Responsible Care efforts ," the council dubbed its One Global Standard of Excellence global Responsible Care implementation manual an industry best practice.


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