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.