"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.
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.