responsible care · responsible care verification report 2011 – nalco canada inc. 2 executive...

RESPONSIBLE CARE®

Verification Report

Nalco Canada Co.May 3 - 4, 2011

Disclaimer

This report has been produced by a team, convened by the Chemistry Industry Association of

Canada (CIAC), to provide advice to the member-company and assist it in meeting its

Responsible Care® commitments. The material in this report reflects the team's best judgment in

light of the information available to it at the time of preparation. It is the responsibility of the

CIAC member-company that is the subject of this report to interpret and act on the report’s

findings and recommendations as it sees fit. Any use which a third party makes of this document,

or any reliance on the document or decisions made based upon it, are the responsibility of such

third parties. Although CIAC members are expected to share the results of this guidance

document with interested parties, the Association, its member-companies, their employees,

consultants and other participants involved in preparing the document accept no responsibility

whatsoever for damages, if any, suffered by a third party as a result of decisions made or actions

based on this report.

Responsible Care® is a registered trademark of the Chemistry Industry Association of

Canada.

Responsible Care Verification Report 2011 – Nalco Canada Inc. 2

EXECUTIVE SUMMARY This report documents the observations and conclusions of the independent verification team tasked with conducting a Responsible Care Verification of Nalco Canada Co. (here after referred to as Nalco) The verification was undertaken on May 3rd and 4th 2011 and included team visits to The Nisku Alberta location. The verification team also conducted interviews with other company personnel and external stakeholders at locations the team was unable to visit. This was the fifth Responsible Care verification completed for Nalco Canada Co. The last verification was completed on September 25th, 26th and 29th 2008. While considering all aspects of the Responsible Care Commitments during this verification the team placed an emphasis on conducting an in-depth examination of company aspects related to The design and construction of Nalco’s new facility in Leduc Alberta, and therefore, Nalco requested that the reverification site visit take place at the Nalco Canada Co. Nisku Alberta manufacturing site. The rationale behind this request is that previous verification site visits (since 1994) have been at the Burlington office and due to the proximity of the Burlington plant there seemed to be more focus given by previous verifiers on the Burlington plant operations and proportionally less focus was given to the Nisku plant and other operations within Canada. The Burlington operations and management systems (plant & office) have not had significant changes since the 2008 re-verification however the operations in Alberta including Nisku, in comparison have. In addition, over the last 5 to 10 years most of the Nalco Canada Co. company management functions (e.g. finance, purchasing, marketing, sales etc.) have been moved from the Nalco Burlington office to the US, therefore there is really no specific driver to assemble at the Burlington office. Nalco expects its presence in Albert to continue to grow over the next number of years. An indicator of this is that Nalco is investing a significant amount of capital to build a new manufacturing plant in Leduc, AB; approximately 4 km from the current Nisku plant. This new plant will be one of the bigger plants for Nalco in North America. The re-verification event would therefore provide a good opportunity to take a look at how Nalco is managing their Alberta growth. As a result of the examination conducted, the verification team is of the opinion that the Responsible Care Ethic and Principles for Sustainability are guiding company decisions and actions, and that a self-healing management system is in place to drive continual improvement. The team believes that the company is capable of responding to the range of Findings Requiring Action identified during the verification that summarized below and discussed in detail in the report. The verification is complete and no further involvement is required by the verification team. Signed: Cameron D. Dillabough Date: May 17th 2011 Verification Team Leader For more information on this or a previous Responsible Care Verification Report, please contact your local company site or the company’s overall Responsible Care coordinator: Dan Orasanin, Sr. Manager Global SH&E Tel: 905-333-6190 - [email protected]


SUMMARY OF VERIFICATION TEAM OBSERVATIONS Findings Requiring Action (Please note: any reference in this section to the CIAC Management System Guide of Plan, Do, Check and Act will be referenced by the acronym PDCA.) 1. There is a finding requiring action to develop a completion time line for addressing the remaining gaps between the RCMS and the Responsible Care® Commitments code elements. 2. There is a finding requiring action to address an identified gap in the RCMS pertaining to “promoting Responsible Care® by name” and “promoting Responsible Care® throughout the value chain” as the team felt that in each of the three codes there was not a specific plan to address these requirements and they will require further analysis by Nalco to be fully implemented in their business activities. Examples would include site contractors, suppliers and municipal governments and service groups. 3. There is a finding requiring action that Nalco Canada Co. develops a managerial process that would ensure corporate entities that provide services on their behalf do so with regard to the requirements and expectations of the CIAC Responsible Care® Commitments. 4. There is a finding requiring action with respect to conducting a gap in the application of the Accountability Code. The team felt the Nalco RCMS was not comprehensive enough to address all aspects of “Operating Site Communities” and “Other Stakeholders”. While Nalco Canada Co. has demonstrated in the past a commitment community dialogue the revised Responsible Care® Commitments includes specific focus areas to address the enhanced code elements. The team recommends a review of the requirements of the Accountability Code and the development of an implementation plan to address all code requirements and identified areas of focus. For example: a) Develop an effective two-way communication plan for the Burlington site based on the risk profile of the Burlington operation. b) Develop a protocol for engaging additional stakeholders within the risk impact zone at the Leduc site. c) Develop a management system for identifying and engaging civic and business leaders and NGOs in communities with Nalco facilities. d) Develop a management system to provide other parties information on the concept of sustainability and the contributions to society that are provided by Nalco products and services. e) Develop a management system to promote Responsible Care® concepts within both the Burlington and Leduc communities with service groups such as the Leduc Chamber Of Commerce and the Economic Development Committee.


f) Develop a management system to provide information, in community communication documents, about the economic and social impacts and the value of Nalco operations in each community. g) Nalco could have been more proactive in involving more local stakeholders within the zone of risk impact of the new Nisku facility, so there is an improvement opportunity to do so with the rest of the first phase of construction, and for the next phase of construction. Improvement Opportunities 1. There is an improvement opportunity to clarify the present code cross reference document by adding a full text description of the relevant Responsible Care® Commitments code element and referencing Nalco policies and procedures by number and or title. 2. There is an improvement opportunity implement and document a process to be proactive in periodically communicating with local and regional elected officials, and civil servants, about community issues that could effect Nalco operations beyond those related to development encroachment. (reference: Accountability Code- Public Policy) 3. There is an improvement opportunity to document a management system that Nalco can utilize to stay abreast of broader public issues, and integrate consideration of these into its decision-making processes, where appropriate. (reference: Accountability Code - Other Stakeholders) 4. There is an improvement opportunity to determine what TransCAER outreach activities are appropriate for each site and develop the appropriate RCMS documentation. (reference: Accountability Code - Transportation Corridors) 5. There is an opportunity for improvement to assess, and implement, if feasible, two recommendations from the Leduc community representative. 1. Consider a pilot project to “inoculate” emergency responders against the trauma involved in responding to events that involve fellow employees. 2. Develop recommendations, possibly in conjunction with a Joint Health and Safety Committee or other employee groups, whereby employees are encouraged to maintain contact numbers and the location of where family members might be relocated during a “shelter in place” emergency event in the community. (reference: Operations Code -Emergency mgt.) Works in Progress 1. The Nalco Logistics group plans to utilize environmental performance, in the form of reduced emissions, as a component of the carrier selection process. (reference: Operations Code - Transportation and Physical Distribution) 2. Nalco is assessing the feasibility of utilizing a prestart up hazard assessment process at customer locations prior to commissioning their production support equipment. (reference: Stewardship Code - Expectations Beyond R&D, opportunities to reduce risk) Successful Practices 1. The Nalco Product Stewardship management system is considered by the team as an industry best practice. Specifically the focus on customer service and promotion of sustainable solutions with


products developed to meet customer’s needs. Examples are the “Safety on Site” training for new sales/ technical representatives, the “Zero Defect” initiative that embodies several Responsible Care® principles and the web site link between the principle of sustainability and product stewardship. 2. The Nalco corporate safety culture assessment system entitled “Assess to Progress” is considered by the team to be an industry best practice. This assessment process provides individual managers a methodology to align their safety management programs with Nalco Corporate Goals. 3. The Nalco Safety, Health and Environment Management System, (Plan, Act, Check and Excel), is based on the PDCA model and is considered by the team a successful practice. 4. The team judges as a successful practices the communication between the CEO and employees via e-mail and the availability of Nalco Corporate communications via “Twitter” and “Face Book”. 5. The team judges as a successful practice the employee work safely promotion of allowing company safety equipment to used for home projects. 6. The team judges the Nalco Export Compliance Checklist, integrated with SAP, as a successful practice. 7. The team judges the “phantom power” analysis conducted at the Burlington site as a successful practice. In the spirit of a Responsible Care® resource conservation initiative the team would recommend sharing this analysis within Nalco and with other CIAC members.


1. INTRODUCTION 1.1 About Responsible Care Verification As a member of the Chemistry Industry Association of Canada (CIAC),the most senior executive responsible for Nalco’s operations in Canada attests annually to CIAC and its peers that the company’s operations conform to the expectations contained in the Responsible Care Commitments and are guided by Responsible Care Ethic and Principles for Sustainability.

As an element of this commitment to Responsible Care, Nalco must, every three years, participate in an external verification intended to:

1. Provide the Executive Contact with an external perspective when assessing if the company is indeed meeting the intent of the Responsible Care Commitments, along with advice on areas that may require attention;

2. Identify opportunities for assisting the company when benchmarking its own practices and performance against those of its peers, thus supporting continual improvement;

3. Contribute to the credibility of Responsible Care amongst company personnel and stakeholders, as well as the stakeholders of the broader industry;

4. Identify successful company practices that can be promoted to peers in the CIAC membership; and

5. Support the identification of areas of common weakness so that collective tools and guidance can be developed to improve performance in those areas across the CIAC membership.

The Responsible Care® Ethic and Principles for Sustainability

We are committed to do the right thing, and be seen to do the right thing.

We dedicate ourselves, our technology and our business practices to sustainability - the betterment of

society, the environment and the economy. The principles of Responsible Care® are key to our business

success, and compel us to:

• work for the improvement of people's lives and the environment, while striving to do no harm;

• be accountable and responsive to the public, especially our local communities, who have the right

to understand the risks and benefits of what we do;

• take preventative action to protect health and the environment;

• innovate for safer products and processes that conserve resources and provide enhanced value;

• engage with our business partners to ensure the stewardship and security of our products,

services and raw materials throughout their life-cycles;

• understand and meet expectations for social responsibility;

• work with all stakeholders for public policy and standards that enhance sustainability, act to

advance legal requirements and meet or exceed their letter and spirit;

• promote awareness of Responsible Care, and inspire others to commit to these principles.


Verification is conducted according to a common protocol, developed by the association’s members and others, including several critics of the chemical industry. The verification is conducted by a team consisting of:

• Knowledgeable industry experts with experience in Responsible Care; • A representative of the public at large (usually with a public interest background and with

experience in Responsible Care gained from serving on the CIAC’s National Advisory Panel) and • One or more representatives of the local communities where the company’s facilities are

located. Once completed, the Verification Report is made publicly available through the CIAC website www.canadianchemistry.ca Nalco is also is expected to share the report with interested persons in its communities and other stakeholders as part of its ongoing dialogue processes. Additional information on Responsible Care and / or the verification process can be found at the CIAC website www.canadianchemistry.ca or by contacting the Responsible Care staff at CIAC at [email protected] or (613) 237-6215 extension 233. 1.2 About Nalco Canada Company. Nalco Canada Co. is a wholly owner subsidiary of Nalco Corporation located in Naperville Illinois. Nalco Canada Co. has been doing business in Canada for 75 years. Nalco Canada Co. was formed as a joint venture between Nalco and ICI in 1936 and began operations in Canada as Alchem Inc. The company operated as Alchem Inc. until 1991 when operations in Canada, India, UK, Taiwan and South Africa became wholly owned subsidiaries of Nalco Co. In 1991 the Canadian operations changed names from Alchem Inc. to Nalco Canada Inc. The name was changed in 2003 to Nalco Canada Co. Throughout the 1990’s Nalco Canada’s operations were increasingly integrated into the North American organization. In Canada, we are the leading provider of integrated water treatment and process improvement services, chemicals, and equipment programs for industrial and institutional applications. In 2010, Nalco Canada Co. achieved sales of more than $220 million (CAD). Nalco Canada has 303 employees (Feb. 10, 2011) and operates 2 manufacturing plants in Burlington ON and Nisku AB, and has technical sales offices in Alberta, Ontario and Quebec. A new manufacturing plant is being constructed in Leduc Alberta to meet the projected western Canada sales growth. For additional Company information access the corporate web site at: www.nalco.com There were two specific Nalco Company entities that were not covered by this verification. TIORCO is a joint venture of Nalco and Stepan Company to globally market custom-engineered chemical solutions that increase production of crude oil and gas from existing fields. Nalco Mobotec provides innovative global solutions to the world's air pollution challenges, offering practical approaches for the control of nitrogen and sulfur oxides (NOx /SOx), carbon monoxide, mercury and particulates.


1.3 About This Verification The verification of Nalco was conducted on May 3rd and 4th and included team visits to the Nisku Alberta site. The verification team also conducted interviews with other company personnel and external stakeholders at locations the team was unable to visit. During the course of the verification, the team had the opportunity to interact with a wide range of company personnel, as well as stakeholders external to the company. Attachment 2 contains a list of those individuals interviewed and their affiliations. This was the fifth verification exercise completed for Nalco. The last verification was completed on September 25th, 26th and 29th 2008. The verification team was comprised of the following individuals.

Name Affiliation Representing

Cam Dillabough CIAC verifier Team Leader

Sherry Kahn CIAC verifier Industry verifier

David Powell CIAC verifier Public-At-Large Verifier

Donna Tona Max Sutton

Nisku resident Burlington resident

Nisku/Leduc community Burlington community


2. TEAM OBSERVATIONS CONCERNING THE RESPONSIBLE CARE COMMITMENTS (CODES AND

BENCHMARK AND COLLECTIVE EXPECTATIONS) During the verification of Nalco Canada Co., the verification team looked for evidence that the company was addressing the expectations documented in the Responsible Care Commitments (152 code elements plus 28 benchmark and collective expectations). While considering all aspects of the Responsible Care Commitments during the verification, the team placed an emphasis on conducting a more in-depth examination of certain company aspects identified by the company or the team. These were related to:

Operations Code Stewardship Code Accountability Code

1. Design and Construction of Facilities and Equipment

2. Operations Activities a. General Considerations b. Laboratory Practice c. Transportation and Physical

Distribution d. Maintenance

3. Safety and Security a. Occupational Health and

Safety b. Process Safety Management c. Emergency Management d. Malicious Intent e. Critical

Infrastructure/Business Continuity

f. Incident Reporting and Investigation

4. Environmental Protection

a. Emissions and Waste Reduction

b. Handling, Treatment and Disposal of Wastes

5. Resource Conservation

6. Promotion of Responsible Care by Name

1. Expectations of

Companies a. Research and

Development (R&D) Expectations

b. Expectations Beyond R&D

2. Expectations of

Companies with Respect to Other Parties

1. Operating Site

Communities

2. Other Stakeholders a. Public Policy b. Finance c. Consumers d. Transportation Corridor e. General Public f. Non-governmental

Organizations g. Business

In communicating its observations, the verification team will make repeated reference to the following categories of observations:


1. Findings Requiring Action document instances where the verification team observes specific company actions (or the absence of company actions) which are inconsistent with the detailed codes and benchmark and collective expectations contained in the Responsible Care Commitments. Where possible, the verification team will communicate, based on their experience and judgment, why it is inconsistent and how the observation relates back to a possible gap in the expected management system and / or the ethic and principles underpinning company actions. The team may also provide advice on how the situation might be responded to.

2. Works in Progress document instances where the verification team has observed the company self-initiating actions in response to identified gaps and deficiency arising from other internal or external audit and review activities, or where the company has self-initiated important improvement opportunities.

3. Successful Practices document instances where the team believes the company has taken actions that strongly support sustained excellence in performance, and which should be communicated throughout the CIAC membership.

4. Improvement opportunities identify instances where the verification team has observed company

actions and decision making as being largely consistent with the expectations detailed in the Responsible Care Commitments, but for which the team is of the opinion that the company could support further improvement by considering alternate or additional benchmarks when undertaking its planning and decision making.

The verification team’s observations of how the company has addressed the Responsible Care Commitments are as follows: 2.1 Team Observations Concerning Operations Code 2.1.1 Design and Construction of Facilities and Equipment The verification team, at the request of the Company, focused on this section of the Responsible Care® Commitments in relation to the construction of a new Nalco facility at Leduc Alberta. The Leduc facility will eventually replace the Nisku operations in response to increased business opportunities in Western Canada. The team reviewed all aspects of site selection, hazard and risk assessments, environmental assessments and dialogue with the Leduc community. It was the consensus of the team that the company had considered all Responsible Care® expectations in the design and construction process. 2.1.2 Operations Activities Laboratory Practice: Appropriate management systems are in place to comply with code requirements. Processes are audited against Good Laboratory Practices which is a quality system of management controls for research laboratories. There will be an improvement opportunity to develop and document an assessment process for contract laboratories.


Transportation and Physical Distribution: Nalco, from a Canadian and Corporate perspective, has a very comprehensive suite of management systems to comply with the code requirements for Transportation and Physical distribution. There is an in-house motor carrier fleet that is integrated with the sales and technical support group to deliver water treatment products to customers and function as a customer support resource if required. A Nalco Best Practice identified by the verification team was an initiative called “Zero Defect delivery” which tracks a customer order from receipt to delivery. 2.1.3 Safety and Security Through manager and employee interviews and a review of documentation housed in the corporate intranet system it was evident that management systems are in place and meet code expectations. Areas such as occupational health and safety, incident reporting and investigation and Process Safety management are particularly strong. During the verification interview process Nalco related the many employee related programs from an Employee Assistance Program to employee wellness programs and promotion of home safety. Several such programs were noted as best practices by the community representatives. As a special note during the hourly employee interviews at the Nisku site, work was halted over the lunch hour so all employees could attend the interview session with the verifiers to further expose all site employees to the verification process. Emergency management Site emergency planning was reviewed in relation to code elements OP31 to OP47. Plans were up to date and have been integrated with respective community emergency response plans. The Nisku community representative is an emergency response professional specializing in trauma counseling and brought to the table many constructive comments in the area of emergency response. Two of these comments, in the area of preconditioning of site emergency responders and maintaining home and work listings of potential shelter in place locations for family members, have been addressed as improvement opportunities. Critical Infrastructure/Business Continuity Code elements OP49 through OP 55 were addressed in this area. Policies and procedures are in place to comply with Responsible Care® expectations. There is in place a Corporate Global Recovery Plan that addresses these code elements. 2.1.4 Environmental Protection The corporate culture of green chemistry and sustainability bolstered by Canadian corporate policies, procedures and green initiatives meets, and in many instances, exceeds the expectations of this code element. For additional information on sustainability and environmental initiatives please visit the corporate web site http://www.nalco.com/sustainability/responsible-care.htm 2.1.5 Resource Conservation Resource conservation is a sub-set of the Nalco green chemistry and sustainability initiatives. The company applies these principles internally with aggressive resource conservation projects with employee involvement that includes employees sharing in monetary savings from resource conservation projects. Externally resource conservation is part of the corporate business plan


highlighted by the “environmental Return on Investment (eROI)” customer focus. Please access the above web site for anecdotal accounts customer successes in this area.

2.1.6 Promotion of Responsible Care by Name Nalco as a world-wide company prominently utilizes and promotes the concept of Responsible Care® and identifies Responsible Care® by name with their products, services and customer business interactions. There is a finding listed that requires Nalco to develop a management system to promote Responsible Care® by name across all three codes. There are also improvement opportunities to promote Responsible Care® at the site level through interaction with contractors, local businesses, service clubs and business associations. 2.2 Team Observations Concerning Stewardship Code 2.2.1 Expectations of Companies Research and Development (R&D) There is not any research and development work in Canada but the various business groups do use third party contract laboratories to perform sample analysis. The team reviewed the Nalco R&D management system in relation to codes ST85 through ST92. It is the consensus of the team that Nalco meets or exceeds the expectations of these code elements. At the corporate level Nalco is a member of the International Council of Chemical Associations and supports the Global Product Strategy that will produce Product Stewardship Summaries for all manufactured chemicals intended as components of Nalco products. At the functional level Nalco has a comprehensive management system for the introduction (Product introduction process) of new products and processes to the market place. An improvement opportunity exists to develop an assessment and Responsible Care® promotion process for third party contract laboratories. Expectations Beyond R&D At the corporate level Nalco is a member of the International Council of Chemical Associations and supports the Global Product Strategy that will produce Product Stewardship Summaries for all manufactured chemicals intended as components of Nalco products. Promotion of Responsible Care® By Name At the corporate level there is an expectation and requirement to promote the Ethic of Responsible Care® and Responsible Care® by name. The Nalco Company web site describes the company’s commitment to Responsible Care® and the link to their Product Stewardship philosophy through the International Council of Chemical Associations. Communication Through the Value Chain The corporate sustainability web site contains an excellent description of how Nalco products contribute to the betterment of society. The team will recommend as an improvement opportunity that the Canadian company utilize this information to further enhance their Community Dialogue management system by disseminating this information to local municipal governments and business associations.


2.2.2 Expectations with Respect to Other Parties The team reviewed the management system in place to attain compliance with code elements ST115 through ST 124. A comprehensive management system is in place that is comprised of “Six Service Standards” that embrace the Plan, Do, Check and Act model as it is applied to the customer service function as a method of promoting safety and Responsible Care® in the value chain. There is a finding requiring action in this section that focuses on the development of a management system that would provide Nalco Canada Co. with assurance that services provided by corporate entities outside Canada do so in consideration of the requirements and expectations of the CIAC Responsible Care® Commitments. 2.3 Team Observations Concerning Accountability Code 2.3.1 Operating Site Communities The verification team did include representatives from the Burlington ON and Nisku/Leduc AB communities. Nalco did have a community dialogue management system in place for each location that had been implemented guided by the 2009 CIAC protocol. The team assessed this community dialogue management system against present Accountability Code elements AC125 through AC136 and will present, in this report, findings requiring action and improvement opportunities pertaining to community dialogue and stakeholder involvement. In the 2008 verification report there were findings and improvement opportunities proposed for previous code elements in these areas and the company had developed procedures to address those findings and improvement opportunities. It is the team consensus that the management system is not comprehensive enough and the company should re-examine the Accountability Code requirements and strengthen the management system(s) to address code requirements. Prior to, and during this re-verification the Burlington plant manager had taken steps to revitalize the community dialogue process at the Burlington site. The team will list findings and improvement opportunities in this area to guide the company in management systems improvements in this area. 2.3.2 Other Stakeholders The team assessed this section of the Accountability Code by reviewing what documented management systems or processes were in place to comply with code expectations. Through the Corporate Code of Conduct, interaction with industry and business associations at the corporate and local level and communication with federal, provincial and local elected officials Nalco embraces the Ethic of these code elements. However, in reference to the principle of “working for public policy”, the team felt that while company efforts in this area supported the previous protocol, the management system is not comprehensive enough to address all the requirements of the 2010 Responsible Care® Commitments. Examples might include; proactive communication on the benefits to the community of Nalco operations, proactive communication to elected officials and civil servants beyond the issues of encroachment and identifying and engaging NGOs in communities with Nalco facilities. The team will list a finding requiring action in this area to guide the company in documenting these processes to align them with the Responsible Care® Commitments expectations.


3. TEAM OBSERVATIONS ON THE COMPANY MANAGEMENT SYSTEM It is a requirement of Responsible Care that companies have a documented, self-healing management system or systems capable of identifying and responding to deficiencies and otherwise supporting continual improvement across all company business units, functions, and sites and as a framework for implementing the Responsible Care Commitments. The verification team studied the Nalco Canada Co. management system(s) and compared and contrasted the attributes of that system(s) to those of a self-healing overall management system as discussed in the CIAC Management System Guide. The verification team’s related observations to the company management system(s) are as follows: 3.1 Observations on the “PLAN” Step During the PLAN step of the management system, the company decides what the goals of the company are and how they will be met. In determining these goals, it is expected the company will look inward across its operations, but also look outward, considering the expectations of stakeholders; regulatory requirements; relevant Responsible Care® Commitments and supporting tools; and other industry benchmarks. In considering the PLAN step of the Nalco Canada Co. management system, the verification team observed the following: The planning process for the Nalco Canada Co. begins at the world wide corporate level (Nalco Company) where periodic management reviews are conducted by various management groups ranging from the corporate board of directors to the individual operational locations in Canada. Based on these reviews and an integrated performance tracking system, including a real time Safety, Health and Environment performance “dash board”, the senior management group can develop a continuous improvement plan for the Corporation. When these plans are developed improvement goals cascade through the company and include individual manager’s key performance indicators. Corporate philosophical concepts such as Responsible Care® and Sustainability are integrated with the planning process and greatly influence the development of goals and objectives. An example two comprehensive management systems that were reviewed by the verification team are the Burlington site “Integrated Loss Control Plan” and the Nalco Company “SHE Management System”. During the verification the team also assessed the results of the cross referencing process and identification of revisions required to the Responsible Care® Management System in support of the Responsible Care® Commitments. The team has identified eleven areas where there are gaps in the application of the commitment protocol. The findings related to these gaps are listed under “Team Observations”. 3.2 Observations on the “DO” Step In considering the “DO” step of the Nalco Canada Co. management system, the verification team observed the following: There is a comprehensive process in place to implement the results of planning and goal setting throughout the organization. Structured ISO management systems for quality, process safety management (PSM) and environmental management are in place at the Canadian operational sites while, in the field, management systems such as “Safety On Site” training for new technical representatives and “Six Service Standards” that integrate the aspects of customer service with


safety, health and environmental management . Performance expectations for employees and managers are explicit and are designed to support the goals, objectives and philosophies of Nalco Company and Nalco Canada Co. 3.3 Observations on the CHECK Step In considering the Check Step of Nalco Canada Company’s management system, the verification team observed the following: At both Canadian sites the management system acronym is “QSHE” which stands for Quality, Safety, Health and Environment. Implicit in this management system are the requirements of a Responsible Care® management system and the Responsible Care® management system policies and procedures are identified by a “RCP” prefix. As part of the structured ISO based management systems for quality, PSM and environmental management each of these systems has an auditing and corrective action function. Audits are performed both internally and by external third parties. Responsible Care® related audit items and verification findings and improvement opportunities are tracked on the Responsible Care Action Tracking system (RCATS). Tri annually, Nalco Canada Co. conducts a “Nalco Compliance Assessment Process” of all sales, logistics and operational areas. In support of the annual Responsible Care® attestation process there are a series of safety, health and environmental (SHE) management reviews ranging from quarterly Board of Director’s meetings and monthly Chairman’s Committee meetings to a similar meeting frequency at the operational and Global H,S & E support group level. Nalco Canada Co. utilizes the Responsible Care® Action Tracking system as a method of annually reviewing compliance with the CIAC Responsible Care® Commitments. There is a very comprehensive set of performance metrics in place that include corporate initiatives in Responsible Care, safety performance and sustainability and CIAC related performance monitoring in worker and contractor safety, transportation incidents, environmental releases and reductions in a member company’s environmental footprint. 3.4 Observations on the ACT Step In considering the Act Step of the Nalco Canada Co. management system, the verification team observed the following. The Nalco Canada Co. SHE management system, in which the Canadian entity participates, utilizes a PLAN, DO, ACT, CHECK; format that is very similar to the CIAC Management System Guide and in the “People, Training and Competence” section lists the policies and programs that have been implemented to improve the SHE performance on the Company. Some of these policies and programs have been referenced in other sections and include: STOP which is a job safety and corrective action program, Safety On Site (SOS) which is a focused safety training program for employees who work alone in the field, Safe T NET which is an intranet based employee training system and safe driving programs aimed specifically at company truck drivers and field sales and technical representatives.


4. TEAM OBSERVATIONS ON THE RESPONSIBLE CARE ETHIC AND PRINCIPLES FOR SUSTAINABILITY Each CIAC member company is formally committed to the ethic of “Doing the right thing, and being seen to do the right thing.” This ethic, along with the principles for sustainability are expected to guide the company’s decision making and practices. In conducting the verification, the team is looking to understand how well the ethic is understood and adopted within the company, and the degree to which the principles inform the manner in which the company does its business. The verification team carefully observed the Nalco Canada Co. decision making processes and actions and compared and contrasted the attributes of those with the attributes of a company guided by the Responsible care Ethic and Principles for Sustainability as discussed in the Responsible Care Commitments (Appendix E). The verification team’s related observations on the company’s application of the Responsible Care Ethic and Principles for Sustainability are as follows: It is the team consensus that Nalco Canada Co. has demonstrated an understanding of the Responsible Care® Ethic and Principles For Sustainability throughout the verification process. Due to the philosophy of the parent company Nalco Canada Co. excels at the application of several of these Principles to their business activities. Two of the Principles, “working with stakeholders for public policy and standards that enhance sustainability” and “promoting awareness of Responsible Care® and inspiring others to commit to these principles”, will require further analysis by Nalco to be fully implemented in their business activities. Nalco Canada Co., through their sustainability reporting, demonstrates their commitment by being participants in United Nations Global Compact and a further commitment to the CEO’s Water Mandate. The Nalco Executive Contact is also an officer of the International Council of Chemical Associations. Thus the company’s goals and objectives, policies and procedures are driven from the Responsible Care® and Sustainability Ethic. The company business plan is based on, “improving people’s lives and the environment”, “being proactive to protect health and the environment” and “understanding and meeting expectations for social responsibility”. In this report there are findings and improvement opportunities that despite having a robust Responsible Care® management system, will aid the company in identifying and addressing gaps in the application of the Accountability and Stewardship Codes.


5. VERIFICATION TEAM CONCLUSION As a result of the examination conducted, and in consideration of the observations communicated within this report, the verification team: Is of the opinion that the Responsible Care Ethic and Principles for Sustainability are guiding company decisions and actions, and that a self-healing management system is in place to drive continual improvement. The team believes that the company is capable of responding to the range of Findings Requiring Action identified during the verification, as summarized in the Executive Summary and discussed in detail in the report. The verification is complete and no further involvement is required by the verification team.


ATTACHMENT 1

COMPANY RESPONSE TO VERIFICATION TEAM REPORT On behalf of Nalco Canada Company I have reviewed this verification report. The observations and conclusions contained in the report have been discussed with the verification team. Nalco will continue in its efforts to improve its Responsible Care® ethic and associated activities by building on our Responsible Care® management system strengths and by addressing the findings & suggested areas for improvement. The CIAC Responsible Care ® Re-verification process was a good exercise for the company to participate in and provided good learning opportunities for Nalco personnel that were involved. Some of the items identified under “Findings Requiring Action” and “Improvement Opportunities” may provide potential for sharing with other Nalco operations. Nalco will assign priorities to the FRA’s and assess the feasibility of Opportunities for improvement provided in this report. The collective re-verification experience under the new CIAC Responsible Care codes and all noted FRA’s and Improvement Opportunities will further Nalco’s commitment to Responsible Care ® and our progress will be shared with our stakeholders. The findings and opportunities for improvement provided by the team will assist Nalco in our continuous improvement relative to Safety, Health & Environment activities. Nalco Canada Co. will communicate the results of the verification exercise with its CIAC peers at their next meeting, and will discuss the verification results with our stakeholders, including those representing communities near our operating sites. We will give consideration to the Improvement Opportunities identified by verification team and will assist the CIAC in communicating and sharing the identified Successful Practices to other CIAC members. Plans will be developed and implemented to respond to the Findings Requiring Action identified by the verification team. Our progress in implementing those plans will be discussed when preparing our Annual Statement of Re-Commitment to Responsible Care, and communicated to the verification team at the time of our next verification. Dan Orasanin Sr. Manager Global SH&E Responsible Care Overall Coordinator Nalco Canada Co. July 25, 2011


ATTACHMENT 2 INTERVIEW LISTS Company Personnel Contacted During Verification Process

Name Position Location

HASANA SISCO SENIOR DIRECTOR, GLOBAL SAFETY, HEALTH, ENVIRONMENT & RESPONSIBLE CARE

NAPERVILLE IL

DAN ORASANIN SR. MANAGER GLOBAL SAFETY, HEALTH & ENVIRONMENT (SHE)

BURLINGTON ON

BRAD HEATH DISTRICT MANAGER WATER & PROCESS SERVICES

CALGARY AB

PERTER WESTERTERP PLANT MANAGER BURLINGTON ON

ROLAND GALLANT PLANT MANAGER NISKU AB

GREG BARRETT LEDUC PROJECT MANAGER LEDUC AB

QUADRI IGE SITE PLANT ENGINEER LEDUC AB

DOUG CLAPPERTON S,H&E LEAD NISKU AB

FRANK HUMPHREYS S,H&E LEAD BURLINGTON ON

STEVE NARASNEK GLOBAL PSM MANAGER BURLINGTON ON

COLLIN TILLMAN CHEMTRAC WEST TEAM LEAD

KELLY MAGURANY NALCO SR.TOXICOLOGIST NAPERVILLE IL

ESTA HALLIDAY SR. SH&E SPECIALIST BURLIGTON ON

LINDA BUNTON TRANSPORTATION SUPERVISOR BURLINGTON ON

DOUG MIERITZ SR, SH&E MGR & CORPORATE RESPONSIBLE CARE COORDINATOR

NAPERVILLE IL

CHEMISTRY INDUSTRY ASSOCIATION OF CANADASuite 805, 350 Sparks Street

Ottawa (ON) K1R 7S8T: 613 237-6215 F: 613 237-4061

www.canadianchemistry.ca

responsible care · responsible care verification report 2011 – nalco canada inc. 2 executive...

Documents