chemistry industry association of canada

CHEMISTRY INDUSTRY ASSOCIATION OF CANADA

Chemistry Industry Association of Canada

June 2013

Recognizing Alternate Approaches to Responsible Care Delivery & Verification

January 2014


Overview

CIAC Needs Task Force Mandate Task Force Approach Task Force Findings Task Force Recommendations Discussion and Next Steps

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CIAC Membership Needs

CIACMembers

& Partners

ACCMembers &

Global Charter companies

active in Canada

Other Canadian Chemistry Interests

Goal : Maximize participation in CIAC

Goal :Increase Participation in CIAC

and Responsible Care

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Task Force Mandate

Reporting to CIAC Technical Management Committee:

• Make recommendations on the degree to which companies whose Canadian operations have been certified to the RCMS (or RC14000) requirements of the ACC should be considered as having met CIAC’s Responsible Care implementation and verification requirements.

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OUR PROCESS

Task Force established (BASF, Chemtrade, Dow, MEGlobal, Methanex, and Nova participants, CIAC).

Comprehensive benchmarking exercise completed:• CIAC Responsible Care Commitments (June 2010) and • ACC Responsible Care (February 2013)

• New Process Safety Code• New Product Safety Code• Increased emphasis on energy efficiency, waste minimization,

resource conservation• ACC provided important information and assistance.

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OUR FINDINGS

Very high degree of similarity overall, especially in:• Management System Expectations;• Operations Code requirements; and • Stewardship Code requirements.

Each had notable areas of emphasis and strengths / weaknesses. Also, some differences: • Most often, matters of terminology, language;

Task Force aimed to identify any substantive differences – where differences could lead to negative outcomes in:

1. Overall credibility of Responsible Care in Canada;2. Demonstrating collective commitments in agreed areas, and / or 3. Equity across CIAC membership.

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OUR FINDINGS

Using these criteria, the Task Force identified the following as areas that met the test for ‘substantive differences” :1. Responsible Care Principles and Ethic2. Leadership expectations3. CIAC benchmark and collective expectations4. Engagement (@ Worse Case Scenarios) at site communities5. TransCAER participation6. Sustainability7. Position on Corporate Responsibility 8. Promoting Responsible Care, by name9. Transparency and public involvement in verification / certification

process.

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Our Primary Recommendation

1) That companies whose Canadian operations are certified in accordance with ACC requirements as having a Responsible Care Management System (RCMS) be considered as meeting the vast majority of expectations contained in CIAC’s Responsible Care Commitments.

Such companies need only satisfy a small number of additional expectations to be considered as members in good standing within CIAC.

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Supporting Recommendations

2) That additional expectations be strictly limited to:a) Meeting the collective obligations of all CIAC members,

namely i. Initial and annual resigning to RC Commitment;ii. Establishing Canadian RC governance (Executive Contact and RC

Coordinator) ;iii. Participation in CIAC Leadership Groups;iv. Submitting performance information annually to CIAC (emissions and

waste, safety, process safety, transportation safety);v. Ensuring process safety, site security, transportation safety, waste

contractor and motor carrier evaluations are delivered in a manner equivalent to CIAC benchmarks; and

vi. Meeting CIAC fee obligations and applicable bylaws.

(Note – these are very similar to additional obligations of companies belonging to the ACC (e.g. statement of commitment, annual reporting of KPI’s. Fee payments, etc.)

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b) AND Meeting CIAC Accountability Code expectations related to I. Site community engagement, including aspects related to Worst Case

Scenario, mitigation, emergency preparation and self-protectionII. TransCAER outreach participation

(In some instances, these are regulatory requirements in the United States. There are no parallel regulations in Canada and these are expectations of ALL CIAC member companies).

ANDiii) Developing and implementing corporate positions on sustainability

(as defined by the company) and corporate responsibility (as defined by the company and meaning engagement and responsiveness with stakeholders beyond the areas of EHS&S).

(These are new obligations that respond to Canadian’s expectations for the future direction for Canada’s chemistry industry.)

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3) To meet CIAC verification expectations, such companies must :a) Include Canadian operations in the scope of the RCMS

certification process every three years;

and

b) Participate in a condensed external verification process (once every three years) to verify Accountability Code expectations are being satisfied in areas related to:

i. Responsible Care Leadership and Ethicii. Site community engagement, including WCSiii. TransCAER participationiv. Developing and implementing corporate positions on sustainability

and corporate responsibilityv. Promoting Responsible Care, by name.

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Proposed Condensed Verification

Two verifiers – team leader and community representative:a) Half day planning and one day site visit. Topics covered include:

i. Companies Responsible Care Leadership and Ethic - key questions for Executive contact.

ii. Outcomes of certification activity and how these were addressediii. Accountability Code – Part I: Site community engagement, including

WCS.iv. Accountability Code Part II: TransCAER participation.v. Accountability Code Appendix A: Company approach to sustainability.vi. Accountability Code Appendix B: Company approach to corporate

responsibility.vii. Promotion of responsible Care by name.

b) Short report to company, and CIAC for public posting. Report includes reference to successful completion of RCMS certification and copy of the certificate.

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Partner and Re-sale CompanyRecommendations

4) Responsible Care Partner organizations and member companies with re-sale only activities in Canada and whose Canadian operations have been included in the scope of RCMS certification processes be deemed to be meeting CIAC expectations.

Such companies need also to meet CIAC collective expectations for Partners (see Slide 9).

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Other Related Recommendations

5) Access and Equality of Membership – recognition of alternate approaches to Responsible Care delivery and verification / certification should be available to ALL existing and prospective CIAC members. No membership tiers.

6) Reciprocity - A similar request should be made to ACC respecting companies predominantly in Canada and with minority of operations in USA.

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Risks and Opportunities

Risks OpportunitiesSome parties may want full CIAC recognition based solely on RCMS certification.

Increased membership – producing companies, partners, resale companies.

CIAC stakeholders may not view process as sufficiently credible.

Opportunity to learn from best practices elsewhere (e.g. New ACC process safety code).

CIAC verification process could be difficult to maintain if significant numbers choose certification approach.

A practicable solution to a long-standing and difficult challenge - in Canada and globally.

Reduced costs for some members.

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Consultations / Review

1. CIAC Verifiers – Jan 13.2. Technical Management Committee – January 30.3. ACC Responsible Care Board Committee – Feb 4.4. Prospective member and ‘at risk’ companies - ongoing5. National Advisory Panel – early February6. Leadership Groups January 27 – February 6

CIAC Board of Directors – February 13

After – Membership marketing materials, further ACC meetings, co-communications with ACC.

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Comments & Questions?

Your turn….

.

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chemistry industry association of canada

Documents

acc responsible care

responsible care companies

responsible care principles

ciac goal

task force mandatereporting

language task force

ciac advocacy environment

new requirements