Can You See Me Now?

Revamped Responsible Care Strives for Transparency

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"Responsible Care changed the culture of an entire chemical industry."

," Barry Stutts, manager of the Responsible Care initiative for Pittsburgh-based Bayer Polymers, at the American Chemistry Council's (ACC) recent Responsible Care conference in Miami

The above statement speaks volumes about an initiative that has driven numerous environmental, health and safety (EH&S) improvements.

To celebrate Responsible Care's 15th anniversary in the United States, ACC is giving the initiative a facelift ," a makeover of ambitious proportions. ACC said the changes strive for transparency, credibility and consistency in performance. Moreover, the new approach encourages involvement at all levels of a company, so you might want to pay close attention to the changes even if you are not currently tasked with EH&S activities.

Why change?

"At no time in history has this industry been as efficient, socially conscious or essential to our well-being," stressed Greg Lebedev, ACC's president and CEO, during the conference's opening session. "Yet, at no time in history have we been viewed with such broad-based suspicion and apprehension. The social proposition that the public loves their way of life, yet fears the people who bring it to them' is untenable."

Unfortunately, Lebedev's observations ring true. Despite their remarkable strides in pollution prevention, safety performance, product stewardship and other areas, ACC member companies have not been completely successful in conveying their Responsible Care stories to a still-wary public. Moreover, actions taken under the original initiative to boost EH&S performance appeared to be losing some steam.

"Frankly, [Responsible Care] was getting stale," said Michael E. Campbell, CEO of Norwalk, Conn.-based Arch Chemicals Inc., chairman of the ACC board committee on Responsible Care and the conference's keynote speaker. During the past few years, many companies have found it increasingly difficult to realize continuous improvement under the initiative, and "at the end of the day, performance is what counts," he maintained.

What to expect

According to Lebedev, the new Responsible Care embraces three attributes: pace, productivity and passion. Under the new initiative, member companies will be able "to move quickly and flexibly to solve problems and add value;" be able "to increase performance through change;" and be able "to mobilize support for core objectives at both the rational and emotional levels."

Perhaps most important, added Lebedev, is the idea of transparency. "Our best defense, as individual companies and as an industry or as a business community, is to take the high road ," to periodically have a conversation within ourselves, but also with society," he maintained. "A conversation that compares what we're doing today with what is expected of us tomorrow; a conversation that demonstrates that we are challenging ourselves to do better; a conversation that proudly points to the transparency of our behavior and performance. That's good governance."

The revamped Responsible Care:

Eliminates the six original Codes of Management Practices, requiring member companies to put into place either a Responsible Care Management System (RCMS) or a Responsible Care/ISO 14001 management system (RC14001).

Strengthens old performance measures and establishes new metrics to measure individual company and industry-wide performance across areas ranging from EH&S to security to products.

Calls for a credible, independent third-party certification of the RCMS or RC14001 at both company headquarter facilities and individual sites.

Establishes a Security Code to help companies safeguard facilities and the surrounding communities.

Tom Grumbles, manager of occupational safety and health for Sasol North America Inc., Houston, stresses that the original codes, all of which ACC members put into place by 1992, are not really disappearing. The codes were fraught with issues and redundancies, he notes, but the basic guiding principles remain ," now embedded within the RCMS and RC14001. Grumbles was involved in shaping the changes.

Responsible Care performance measures combine existing and new metrics and make a few changes related to reporting. Many of these revisions center around documentation. Perhaps the most significant of these changes, however, are the new greenhouse gas and energy-efficiency metrics ," tracked in pounds of carbon dioxide equivalent net emissions per pound of production and in Btus consumed per pound of production, respectively.

Companies must begin to report these new metrics in 2004.

As for the new management system approach, Grumbles believes it will "bring a management profile to the scope of Responsible Care in any location and result in more attention to detail and better decision-making on where resources and efforts will be allocated."

The approach also promotes transparency, stresses Laura Tew, director of stakeholder relations for Arch Chemicals. "Throughout the RCMS technical specification, there is the thread of stakeholder involvement and communications," she says. "Specifically, in the policy and leadership element of RCMS there is a requirement that the policy shall promote openness with stakeholders.' Building on that requirement, there are specific references to include public input and dialogue with the key stakeholders."

RCMS or RC14001?

Companies essentially have two certification options, says ACC. All companies must certify that they have an RCMS in place. They may either undergo the RCMS certification or choose the RC14001 certification, which enables companies to meet the requirements of Responsible Care and ISO 14001 at the same time.

Certification is to be undertaken by independent third parties specially trained in EH&S, safety and security management systems, as well as in Responsible Care. For the RC14001 certification process, registrars and their auditors must meet both Registrar Accreditation Board and ACC requirements, and routine surveillance audits also are required.

BASF Corp.'s Wyandotte, Mich., site was the first to go through the RC14001 process ," a decision that was supplier driven. Wendy Finnerty, director of corporate quality for BASF, was involved from day one. She believes the management system approach presented by both RCMS and RC14001 is key to achieving the transparency the new initiative seeks. "We want the public to see that we welcome a review by a third party because we're proud of what we've accomplished," she stresses.

Arch Chemicals' Rochester, N.Y., facility decided to go the RC14001 route after reviewing ACC technical specification and guidance materials, says Arch's Tew. "Since that facility was already implementing the international environmental standard, ISO 14001, the facility decided that a more integrated approach to Responsible Care would be a great asset and benefit to them," she says. "Although it was not specifically driven by customer demand, we feel that there will be significant customer recognition of the business value of RC14001 certification."

Arch Chemicals, adds Tew, anticipates a combination of RCMS and RC14001 certifications at its various facilities. The decision will be up to each business unit and location.

Cost can become a major issue with RC14001. Although Bayer's Stutts personally sees a benefit to "going that route," he admits the decision probably will be supplier-driven. Moreover, he says, the RCMS is not really less rigorous and still requires a substantial amount of work.

"But I think the cost savings that you're going to get by not requiring every facility to go through the [RC14001]certification and the surveillance audits is essential to the long-term viability of the industry," says Stutts. "Economics are a big issue right now."

No matter which system ultimately is selected, says BASF's Finnerty, a team approach to the certification process is essential. "Establishing all the key interfaces among various areas within the company ," corporate, purchasing, logistics, human resources and EH&S ," was quite a challenge," she emphasizes, "but it was worth the effort."

Smaller companies without extensive in-house expertise would be wise to use other organizations as consulting resources to get through the management system certification process, notes Finnerty, and ACC can assist in resource location. In addition, numerous guidance documents are located on the ACC member Web site.

Bayer's Stutts recalls a Responsible Care saying he heard years ago: "Rob and steal shamelessly." Companies should be willing to adopt something that somebody else already has put into place, he says. "If somebody's willing to share it, use it as a foundation."

But it's not my job

Traditionally, the onus has been on chemical company EH&S personnel to carry out the requirements of Responsible Care. The recent radical changes, however, have the potential to bring those duties into every facility job description ," and that includes plant-level engineers and operators.

Bayer's Stutts sees the changes as an opportunity, not a burden, to employees. "I think, at least within Bayer, this has really been an opportunity to change the philosophy of Responsible Care," he stresses.

"In the old school," says Stutts, "the safety person was responsible for the safety program; the environmental person was responsible for the environmental program; the quality person was responsible for the quality program ," if there even was a quality program 15 years ago in the organization. Really, now what we're trying to do is to move away from that and have those individuals be the subject matter experts. The people that are doing the health, safety, environmental and quality implementation need to be the people that are doing the work, the ones who are out there making the product, that are reengineering the processes." Training will be key to successfully working Responsible Care responsibilities into employee job descriptions, he adds.

Stutts also believes in the "employee as ambassador" concept to help promote transparency within the industry. "If we educate them in what we are doing, then we not only can use that same educational information for the public, but our employees are then able to do that as well," he says. "The public is going to believe their neighbors much faster than they'll believe the plant manager."

That education also extends to formal community outreach programs. Expect more opportunities for community involvement, perhaps as a member of an existing or new community advisory panel or through facility-initiated community service, to further the transparency goal.

In many facilities, plant engineers and operators will undergo specific training related to new Responsible Care metrics and management systems. The metrics also will require additional documentation on the part of many plant personnel.

"Companies will be involved in developing the supporting data for the new metrics," notes Sasol's Grumbles, "and more impact will be seen from reporting these metrics. Where the attention may have been on SARA 313 emissions and employee occupation incident and illness rates, now the attention will go to energy efficiency and an expanded list of emissions."

As subject matter experts, Stutts envisions the plant and process engineers as instrumental players in formulating the strategy to pull all the metric-related information together ," not only to report the information to ACC in a "credible and logical fashion," but also to report it to plant employees and the community.

"The old adage is what gets measured gets done,'" says Stutts. "If we're measuring energy efficiency and we're measuring greenhouse gas emissions [we need] to have those people involved right from the start."

Plant decision-makers also might find themselves serving as key members of an RCMS or RC14001 certification team.

"When you implement a management system like this, it really has to be a comprehensive organizational decision," insists BASF's Finnerty. "In that respect, plant-level decision-makers play important roles in terms of building support and providing training for their people. Also, when you look at processes, you should definitely involve the plant people because they're the ones who specifically know the details of plant operations."

Arch Chemicals' Tew agrees. "The new management system approach will make Responsible Care an integral part of plant operations and not just a standalone EH&S function," she emphasizes. "The management system approach seeks to align employee work activities with specific objectives and targets to improve Responsible Care performance."

At the RCMS third-party certification milestone, employees will be subject to interviews to demonstrate knowledge and commitment to the initiative, adds Tew. Moreover, documents and records maintained by the employees will be reviewed during this process to ensure the RCMS is both in place and working.

Whatever your job function, expect a more team-based approach to Responsible Care ," although it certainly won't happen overnight.

 

What about SOCMA?

Where do these changes leave the Synthetic Organic Chemical Manufacturers Association (SOCMA), which adopted Responsible Care in 1990?

SOCMA staff and members adopted the Security Code and have been involved from "day one" on the RCMS development and the certification, stresses Bayer's Stutts. ACC viewed the association's involvement as critical to the revamped initiative's success. "Even though ACC represents, from a production standpoint, 80 percent of production volume," says Stutts, "they really only represent 20 percent of the production facilities."

SOCMA President Joseph Acker says the association has sought out comments and ideas from member companies, and has worked with its ACC counterparts "to make sure ideas and concerns of the specialty-batch sector were addressed every step of the way."

SOCMA's Responsible Care committee and board of governors reviewed the initiative's changes, says Acker, and approved the final program components. They are recommending that member company representatives adopt the new approach. Ultimately, SOCMA members will have the final say on adoption during a vote this September at the association's annual business meeting in Cambridge, Md.

"More than 80 percent of survey respondents indicated a familiarity with the new program components," says Acker, "[and] 73 percent already use management systems and 86 percent currently track environmental performance." Although SOCMA members indicated the changes would "increase knowledge and control of EH&S issues by all employees, as well as improve environmental performance and customer confidence," they also expressed concern about the cost and business value associated with adoption of the changes, he notes.

Need assistance?

Remember: No one need go it alone. ACC staff provides a number of tools and also can recommend companies that will be able to push you and your facility in the right direction. Some avenues of assistance are listed in the box below.

Responsible Care Implementation Resources

www.responsiblecaretoolkit.com for tools, technical support and other assistance.

Responsible Care regional coordinator groups.

ACC Responsible Care staff (click on the Responsible Care link at www.americanchemistry.com).

Responsible Care workshops.

Other facilities with implementation experience. Again, ACC staff can point you in the right direction.

 

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