purpose - responsible care...1.1 to ensure that that the american chemistry council’s (acc)...

Procedure RC501.1 American Chemistry Council

Responsible Care® Third-Party Audit Requirement Requirements for ACC Members and Responsible Care Partners

RCMS®/RC14001®

October 2017 1

1.0 PURPOSE

1.1 To ensure that that the American Chemistry Council’s (ACC) Responsible Care Third-Party Audit requirement sustains public confidence and acceptance by defining its requisites for ACC members and Responsible Care Partners.

2.0 SCOPE

2.1 This procedure applies to all ACC member and Responsible Care Partner Companies

unless otherwise noted.

2.1.1 Responsible Care Partner Companies in the rail, marine and bulk liquid storage sectors have the option of using sector-specific certification options described in RCxxx. (to be developed)

2.1.2 ACC Affiliate and Associate members are not subject to this procedure.

2.2 All businesses, operations, including corporate and/or divisional headquarters and

facilities of an ACC member or Responsible Care Partner company that are considered to be in its calculation for ACC membership or Responsible Care Partnership status are subject to this procedure.

2.3 This procedure does not apply to an ACC member’s and Responsible Care Partner’s joint

ventures or similar entities where the member or Responsible Care Partner company does not exercise controlling interest.

2.4 Any clarification necessary on which facilities this procedure applies, shall be defined by

ACC.

3.0 TERMS AND DEFINITIONS 3.1 American Chemistry Council (ACC) – the primary trade association representing the

business of chemistry in the United States. It is the sponsor of Responsible Care in the US (www.americanchemistry.com).

http://www.americanchemistry.com/



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3.2 ACC Audit Cycle – Three-year intervals established by ACC during which members and Responsible Care Partners must complete their Responsible Care Third-Party Audit Requirement.

3.3 Responsible Care Third-Party Audit Requirement – Successful completion of RCMS or RC14001 audits at the ACC member’s/Responsible Care Partner’s headquarters and a sample of facilities which is based on ACC’s membership/Partnership calculations. Members/Responsible Care Partners must successfully complete the required audits by demonstrating conformity to the requirements found in the RCMS Technical Specification, RC14001 Technical Specification or a combination of the two options within each ACC Audit Cycle (See Section 4.1.4.3). ACC member and Responsible Care Partners fulfill this requirement as an obligation of membership/Partnership.

3.4 Audit Service Provider (ASP) – The third-party auditing company that is employed to conduct RCMS/RC14001 audits. If certification is to the RC14001 Technical Specification then the ASP may also be referred to as a certification body (CB).

3.5 Audit Sample Group – A sub-group of facilities of a larger group of facilities that have

been selected for RCMS/RC14001 audits to meet the Responsible Care Third-Party Audit Requirement (See Section 4.3). ACC companies are required to successfully complete audits at their HQ plus a sample of their facilities to satisfy the Responsible Care Third-Party Audit Requirement.

3.6 Facility – for purposes of this procedure, defined as a location falling under an ACC

member’s/Responsible Care Partner’s dues calculations at which commercial chemicals are manufactured, handled, transported, stored and where employees or others working on behalf of the ACC member/Responsible Care Partner are present.

3.7 Headquarters – for purposes of this procedure, the administrative functions by which the Responsible Care/EHSS activities are managed and directed for the organization being audited/certified. A Headquarters may be centralized in a stand-alone location or be a decentralized arrangement with Responsible Care/EHSS activities managed among individuals and teams at different locations.

Note: In some cases an ACC member/Responsible Care Partner may only have a Headquarters location with administrative offices and no associated facilities.

3.8 Responsible Care – a global environmental, health, safety and security performance initiative which was established in Canada in 1985 and adopted by the ACC in 1988. Responsible Care is an obligation of membership for ACC members and Responsible Care Partners. The initiative’s goals are continuous improvement and responsiveness to stakeholders’ concerns about the chemical industry’s products and operations.

3.9 Responsible Care management system(s) –This term with “management system(s)” in

lower case refers to a comprehensive environment, health, safety and security management system(s) whose requirements are defined in the Responsible Care Management System® (RCMS®) or RC14001® Technical Specifications.



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3.10 RCMS® – An option for certification under the ACC’s Responsible Care initiative. The

requirements for RCMS can be found in ACC’s document RC101 (current version) RCMS is intended for use by ACC members and Responsible Care Partners within their US and Canadian operations.

3.11 RC14001® – An option for certification under the ACC’s Responsible Care initiative. The

requirements for RC14001 can be found in ACC’s document RC151 (current version). RC14001 certification is available to any organization regardless of sector, affiliation or geographic location. (See also RC503)

3.12 Small company – ACC member company/Responsible Care Partner company reporting

<1 million employee exposure hours under ACC’s Occupational Injury and Illness Report (OIIR) metric (per OSHA 300 requirements and OSHA definition of small business = < 500 employees).

3.13 Stage 1 Audit – audit to determine if an organization is ready for a

certification/conformance audit (Stage 2). For RCMS, the ASP will confirm that the Technical Specification’s key requirements are being met; it will confirm legal compliance; implementation status; confirm risk/complexity of facility; and the scope of certification. The output of this audit will be a report identifying any potential non-conformities that the organization will have to correct before Stage 2 audit. ISO 17021-1 requirements for Stage 1 audit are applicable to RC14001.

Note: “Potential non-conformities” may also be identified by other terms provided the ASP is consistent in

their use.

3.14 Stage 2 Audit – an audit to evaluate the implementation and effectiveness of the

organization’s management system(s). During this audit, the ASP will determine the degree of conformance with the Technical Specification’s requirements, and report any nonconformity that the organization will have to correct before certification can be granted. ISO 17021-1 requirements for Stage 2 audit are applicable to RC14001.

4.0 RESPONSIBILITIES

4.1 General

4.1.1 Fulfillment of ACC’s Responsible Care Third-Party Audit Requirement is a mandatory element of the ACC’s Responsible Care initiative. All ACC members and Responsible Care Partners shall obtain certification to RC14001 or RCMS (Option 1) or demonstrate conformity to RCMS (Option 2) as required in this procedure to maintain their standing in the ACC’s Responsible Care program.

Table 1 below provides a comparison of RCMS Option 1 and RCMS Option 2.



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Table 1

RCMS Option 1

RCMS Option 2

Scope Certification of Management System

Documents conformance to the management system

Audits Certification audit at HQ and/or facilities

Conformance audit at HQ and/or facilities

Annual Surveillance Audit(s) HQ and/or facilities None

Company-wide RCMS certification

Available (may require larger sample size than identified below in Section 4.3.3, Table 2; see also 4.1.4)

Not available

Type of ASP Acknowledgement Certificate Statement of Conformity

ACC Requirements Both Option 1 and Option 2 fulfill Responsible Care Third-Party audit requirement

Note: See Appendix 3 for decision tree chart.

4.1.1.1 ACC members and Responsible Care Partners can find information on

their Responsible Care Third-Party Audit Requirement and Code

implementation schedules in their company’s Responsible Care

Coordinator “welcome letter.”

Note: ACC members/Responsible Care Partners can assist in audit planning by sharing

“welcome letter” information with the ASP when planning for the audit.

4.1.1.2 If clarification is needed on the ACC member’s/Responsible Care

Partner’s Responsible Care Third Party Audit Requirement schedule, it

shall consult ACC’s Responsible Care & Value Chain Outreach

Department. (see Appendix 2 for contact information)

4.1.2 The ACC member or Responsible Care Partner shall be responsible for demonstrating conformity to the requirements found in the RCMS Technical Specification or RC14001 Technical Specification through (a) third-party audit(s).

4.1.2.1 RC14001 audits are conducted consistent with ISO 17021-1 initial

certification. RC14001 also requires periodic surveillance audits to

maintain certification and recertification.

4.1.2.2 For RCMS audits (Option 1 or Option 2), determination of whether to

conduct both Stage 1 and 2 audits or to combine them in a single audit



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based on a company’s readiness shall be made in consultation with the

ASP.

Note: While not required under the RCMS option, Stage 1 audits are recommended for

companies conducting their initial RCMS audits at their headquarters and/or facilities or if

a company changes ASPs.

4.1.2.3 Under RCMS, companies’ HQ and/or facilities may opt for periodic

surveillance audits (Option 1) to maintain certification and obtain a

RCMS Certificate (as opposed to a Statement of Conformity – RCMS

Option 2). If surveillance audits are elected, the company and ASP shall

determine the frequency and scope of these audits.

Note: For RCMS purposes, ASPs and clients may find ISO 17021 and IAF requirements

helpful in establishing surveillance schedules.

4.1.3 Companies have the option to choose RCMS for some facilities and RC14001 for

others. In all cases, conformity to the requirements of the Technical

Specification being audited at the location is required. In situations where a

company opts to “mix” RCMS with RC14001 audits across its organization,

Certificates or Statements of Conformity shall be discrete for each covered

location(s). When RC14001 is selected for (a) location(s), relevant ISO 17021-1

and accreditation requirements must be adhered to including relationships

and/or interdependency with other facilities.

Note: ACC Members/Responsible Care Partners are reminded that other ACC Responsible Care

program elements (e.g., performance reporting status, Code implementation, etc.,) are considered

auditable under both RCMS/RC14001.

4.1.4 Companies may elect to obtain RC14001 or RCMS (Option 1) which covers

multiple locations under a single certificate.

4.1.4.1 Under the RC14001 option, the process shall conform to International

Accreditation Forum’s Mandatory Document 1 (current version) and

other relevant IAF documents.

Note: IAF MD 1 may require a larger sample size than the Audit Sample Group

determined by the ACC formula in Section 4.3.3, Table 2.)

4.1.4.2 Under the RCMS option (RCMS Option 1 only), the process shall

conform to International Accreditation Forum’s Mandatory Document 1

(current version) and other relevant IAF documents.



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Note: IAF MD 1 may require a larger sample size than the Audit Sample Group

determined by the ACC formula in Section 4.3.3, Table 2.)

4.1.4.3 Certification of multiple locations under a single certificate shall be to

either RC14001 covering all the locations or RCMS (Option 1) covering

all the locations. There shall be no “mixing” of RC14001 and RCMS

(Option 1) audits under a single certificate.

4.2 Auditing Firms

4.2.1 RCMS/RC14001 audits shall be conducted by auditing firms which have been approved/accredited for these services by the ANSI-ASQ National Accreditation Board (ANAB).

4.2.1.1 ASP requirements for RCMS providers can be found in RC502 (current

version) and for RC14001 providers in RC503 (current version).

4.2.1.2 If clarification is needed regarding the ASP’s credentials, see Appendix 2.

4.2.2 Any disputes over an ASP’s credentials shall be resolved prior to the start of an

audit.

4.3 Determining the Number of Required Audits

4.3.1 The Responsible Care Third-Party Audit Requirement includes audits at the ACC Member’s/Responsible Care Partner’s headquarters and a sample group of facilities as defined in Table 2 below.

4.3.2 The ACC Audit Cycle occurs on a three-year timeline as defined by ACC. At least

once in every ACC Audit Cycle the headquarters shall be audited to ensure

continuity of the management system between the headquarters (HQ) and

facility operations.

4.3.3 Audits shall be initiated on a timetable consistent with the ACC Audit Cycle schedule presented below. The schedule shall be renewed every three years. Each Audit Sample Group shall consist of the Headquarters (HQ) and a selection of facilities. For purposes of calculating the number of facilities required using the 33% requirement in Table 2 below, fractions of facilities greater than or equal to a fraction of 0.50 shall be rounded up to the next whole number and.49 and less shall be rounded off down to the previous whole number.



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Table 2

Company Size Requirements

Per designated ACC Audit

Cycle

1 - 25 facilities

33% of facilities(up to a maximum of

4) + HQ

Complete all required

audits.

26 - 40 facilities 6 facilities+ HQ


audits

41+ facilities 8 facilities+ HQ


audits

Note: ACC Audit Cycle at the time of the publication of this document extends from January 1, 2017 – December 31, 2019. The next ACC Audit Cycle begins on January 1, 2020, etc.

4.3.4 Unless the number of the ACC Member’s/Responsible Care Partner’s eligible

facilities makes this requirement mathematically impossible, at least 2/3 of the

Audit Sample Group shall be facilities that have not undergone a certification

audit in the previous cycle.

4.3.5 The details of the selection methodology used to determine the Audit Sample Group shall be developed and agreed to by the ACC Member/Responsible Care Partner and the selected ASP. In the event an ACC Member/Responsible Care Partner uses the services of two or more ASPs (different ASPs at different locations), it shall be the responsibility of the Member/Partner to coordinate planning and alignment between itself and its ASPs.

4.3.6 Headquarters’ selection may be made based on geographic location, business affiliations with facilities, and other factors. ACC members/Responsible Care Partners and their ASPs are encouraged to manage audit scope and travel schedules to promote efficiency in auditing headquarters processes that are performed at different locations. If a company’s HQ is located outside the United States, a business unit within the US may be designated. Note: Clear definition and agreement on the scope and interfaces of the headquarters and facility

management systems is an important consideration in planning these audits. 4.3.6.1 When conducting a headquarters audit for RC14001, the company and

its ASP shall ensure conformance with all relevant ISO procedural requirements.



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4.3.7 Selection of the appropriate Audit Sample Group may be made considering measures relating to relevant risks, as well as other factors such as randomness, facility size, stakeholder perceptions, geographic location or complexity. 4.3.7.1 Both the ASP and the ACC Member/ Responsible Care Partner shall

ensure that the selection of facilities for the Audit Sample Group is not directed only towards pre-determined or “flagship” locations.

4.3.7.2 When conducting facility audits for RC14001, the company and its

certification body shall ensure conformance with all relevant ISO procedural requirements.

4.3.8 Facilities which are new to the ACC Member/Responsible Care Partner are

excluded for three years from those facilities that are considered when

determining the Audit Sample Group.

Note 1: This includes newly-acquired facilities and/or newly-built facilities.

Note 2: ACC members/Partners seeking certification of multiple locations under a single certificate

(See Section 4.1.4) should consult with their ASP on determining how to bring new facilities under

the certificate in the most efficient and effective manner.

4.3.9 Member companies meeting ACC’s definition of “small” are allowed to combine their HQ audit with an adjacent facility into a single audit. This single audit shall meet the company’s HQ audit requirement and one facility audit requirement. (See Appendix 1)

4.3.10 The ACC member/ Responsible Care Partner shall maintain a record of the

methodology and justification used to select its Audit Sample Group and

subsequent certification of each facility in accordance with its internal

document retention policy.

4.3.11 ACC reserves the right to establish agreements with other Responsible Care

organizations regarding RCMS/RC14001 certification which may affect elements

of this process such as Audit Sample Group makeup and facility location.

Agreements of this type will be developed under existing ACC processes under

direction of appropriate ACC program committee(s) and addressed through

separate Memorandums of Understanding and communicated to all relevant

parties.

4.4 Public Participation

4.4.1 ACC Members/ Responsible Care Partners may choose to include public

participants in their audit processes for both the Headquarters and facility



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audits. If public participants are to be included on an audit, ACC Member/

Responsible Care Partner and ASP shall determine how this part of the process

will be implemented.

4.5 Security-related Items

4.5.1 Security is a component of both the RCMS and RC14001 Technical Specifications and subject to review. ACC members/Responsible Care Partners shall ensure that arrangements are made prior to the start of an RCMS/RC14001 audit regarding ASP access to security-related materials. ASPs and their clients shall work together to ensure that security-related information is protected and legal restrictions are followed while not compromising the integrity of the RCMS/RC14001 audit.

Note: The use of auditors who are Chemical-terrorism Vulnerability Information (CVI) Authorized Users may alleviate concerns regarding access to security-related information.

4.6 Reporting Status

4.6.1 The ACC Member/Responsible Care Partner shall report its RCMS/RC14001 status to ACC as part of its Responsible Care performance reporting obligation.

4.6.2 ACC members/Responsible Care Partners are encouraged to publicize their RCMS/RC14001 status to their stakeholders.

5.0 RECORDS GENERATED

5.1 Summary of selection methodology and justification, and Audit Sample Group (ACC member/Responsible Care Partner)

5.2 Audit Reports for each facility and headquarters (Audit Service Provider, ACC member/ Responsible Care Partner)

5.3 Certificate (RC14001 or RCMS Option 1) or RCMS Statement of Conformity (RCMS Option 2)

6.0 REFERENCE DOCUMENTS

RC101 – RCMS Technical Specification (current version)

RC151 – RC14001 Technical Specification (current version)

RC502 – RCMS ASP requirements (current version)

RC503 – RC14001 Requirements for Accreditation Bodies, Certification Bodies, Organizations

and American Chemistry Council (current version)

RC205 – Responsible Care Certification Auditor Qualification and Training Requirements

(current version)

RCxxx – Sector-specific Certification Options (current version) (to be developed)



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ISO 17021 – Conformity Assessment – Requirements for Bodies Providing Auditing and

Certification of Management Systems (current version)

7.0 REFERENCE LINKS ACC Website: www.americanchemistry.com

IAF Mandatory Directive 1:2007

www.iaf.nu/upFiles/IAFMD12007_Certification_of_Multiple_Sites_Issue1v3Pub5.pdf

http://www.americanchemistry.com/

http://www.iaf.nu/upFiles/IAFMD12007_Certification_of_Multiple_Sites_Issue1v3Pub5.pdf



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APPENDIX 1 - Special Case: Small Company Option

In an effort to define specific boundaries of flexibility in the ACC’s Responsible Care Third-Party Audit Requirement while maintaining its integrity and purpose, options for companies that fall into very specific and limited “special case” categories are detailed below. The two special case categories, qualification criteria, and certification options are summarized below. Special case options are offered to “small” companies, as defined below under existing ACC definitions, and would result in the combined headquarters and facility audits for all qualified, self-nominated members/Partners.

Small Company Scenario A Qualifying criteria:

a. ACC Member or Responsible Care Partner must qualify as a small company (See Item 3.12) The Company’s employee OIIR data (which is reported annually to ACC and includes annual exposure hour totals) will be used to determine whether it is considered “small” and in scope for this special case.

b. The company has a facility and headquarters (HQ) that are adjacent geographically and both of which are subject to the Responsible Care Third-Party Audit Requirement.

Requirements:

a. The Company must complete the combined HQ-facility audit by the end of the current ACC Audit Cycle.

b. Companies that conduct combined audits and have additional required facility audits in their Audit Sample Group must complete other required facility audits by the end of the current ACC Audit Cycle.

Small Company Scenario B Qualifying criteria:

a. ACC Member or Responsible Care Partner must qualify as a small company. (See Item 3.12). The company’s employee OIIR data (which is reported annually to ACC and includes annual exposure hour totals) will be used to determine whether it is considered “small” and in scope for this special case.

b. The Company has a "minimal" level of Responsible Care activities at its HQ. The company may elect to conduct a combined HQ-facility audit by bringing HQ staff and appropriate documents and records to a facility for combined audit. In this situation, both the HQ and facility functions are subject to the audit. For companies opting for a RC14001 audit, it may still be necessary to conduct separate audits at the HQ and facility in order to conform to relevant ISO requirements. The company shall consult with its ASP regarding conduct of RC14001 audits under this scenario.



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Certification Requirements:

a. The Company must complete the combined HQ-facility audit by the end of the current ACC Audit Cycle.

b. Companies that conduct combined audits and have additional required facility audits in

their audit sample must complete other required facility audits by the end of the current ACC Audit Cycle.

If a company or its ASP requires clarification on its status as a small company, please refer to Appendix 2 ACC Contact Information for questions.



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APPENDIX 2 – ACC Contact information

For information regarding the ACC’s Responsible Care Third-Party Audit Requirement, please contact:

Daniel Roczniak Senior Director, Responsible Care and Value Chain Outreach 700 Second Street NE Washington, DC 20002 202-249-6191 [email protected]

Inquiries may also be sent to ACC at:

[email protected]

RC14001

To purchase a copy of the RC14001 Technical Specification (www.americanchemistry.com/store )

mailto:[email protected]

mailto:[email protected]

http://www.americanchemistry.com/store



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Appendix 3 - RCMS/RC14001 Decision Tree (for reference only)



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DOCUMENT CONTROL

Name and Title Signature Date

Written By: ACC Procedures Task Force Andy Piper, Chair

9/15/2017

Owner: ACC Responsible Care Committee Maria Krysa, Chair

10/30/201

Approved By: ACC Responsible Care Committee Maria Krysa, Chair

10/30/201

REVISION LOG

REVISION

NO:

REASON FOR CHANGE(S):

DATE:

01 This document along with new RC502 and RC503 replace previous RC201

and RC204 documents.

10/30/2017