Responsible Care®

The structure of the Responsible Care MSV protocol is designed to evaluate five management systems that can apply to all of the Responsible Care Codes. Attributes were created to reflect common threads and finally open-ended Questions, which reflect these attributes, were developed. While this process is not designed to determine the implementation of the 106 Codes of Management Practices that make up Responsible Care, each of the Codes were considered in the development of the protocol.

The five Management Systems are:

1. Policy and Leadership
2. Planning
3. Implementation, Operation and Accountability
4. Performance Measurement and Corrective Action
5. Management Review and Reporting

The Attributes are based on analysis of the Responsible Care Management Practices and describe the necessary systems, organization and policies for a group of management practices. These attributes make up the backbone of each management system and are the basis for the evaluation of each system.

The Questions were derived from the attributes and the Responsible Care Codes of Management Practices. They are open-ended and intended to evoke discussion, demonstration, example, etc. "Yes-No" or "Check-List" types of questions were avoided.

The facilitator coordinates activities with the company several months before the actual verification. The company is provided with appropriate documentation including the MSV protocol, questions sorted by interviewee, and typical panel organization. The company arranges all logistics and schedules and identifies and prepares the appropriate interviewees.

The interview process is done by combining several functional areas (e.g., Purchasing, Contracting, and Transportation or Environmental, Health, Safety and Emergency Response) and scheduling panel interviews in a conference room (1-2 hours each). During the day several of the verifiers, including the community participant will make phone calls to second and third parties in a nearby office or conference room equipped with a speakerphone.

In addition to the panel interviews and calls to second and third parties, the site visits include random employee interviews through a plant walk-around. Neither of these activities is formally scheduled and will take place while the remainder of the verification team is conducting panel interviews.

In order to expedite the interview process, panels of interviewees are created that group similar functions. The proper panel structure and schedule will be the result of collaboration between the MSV consultant and the company. The identification of these panels needs to be completed at least one month prior to the actual verification. Attachments 4 and 5 are examples of typical panels for both a corporate and plant interviews.

During the on-site verification, the team will make phone calls to second and third parties and interview them about the company’s Responsible Care outreach. Prior to the on-site verification the company will identify at least two contacts for each of these second and third parties. They must be notified to advise them that they will be interviewed by the verification team. It is appropriate to review the questions with these contacts. The list of companies and/or individuals with phone numbers will be provided to the verification team on or before the day of the on-site verification. One or more of the team members will leave the panel interviews and use an available office or conference room with a speaker phone to make these calls throughout the course of the day. It is appropriate for the community representative to participate in this process.

During the course of the day one of the industry verifiers and the community representative(s) will take a short plant tour for the purpose of random interviewing of employees. This is not tour of the process. The purpose of the tour is employee contact. If contractors are encountered in the course of the tour they may be interviewed as well.

The report that follows the on-site verification will be prepared by Verrico Associates and will reflect the input of the verification team. It is constructed as follows:

• A short Executive Summary that summarizes the process, scope and findings
• Several sections relating to the Process and Methodology
• A section of Findings and Opportunities
• A Summary of the Opportunities
• A detailed listing of the Verification Team Observations as an Appendix

The report focuses on the company’s Responsible Care management systems. It features site specific examples as support for these company-wide systems

Verrico Associates will send the draft report to the company within 30 days of completion of the verification visit for review of factual information. The draft report is also sent to the verification team and to CMA’s legal counsel for appropriate review. It is the company’s responsibility to determine if it will be reviewed by the community representative(s). Only one copy of the final report will be issued to the company’s executive contact.

The verification focused on processes for implementing Responsible Care and an evaluation of the management systems necessary to ensure the sustainability and continuous improvement of health, safety, and environmental performance. The verifiers evaluated employees’ understanding of Responsible Care and of health, safety, and environmental processes. The team looked for systems that establish and meet appropriate levels of performance; provide for outreach to all stakeholders; assign responsibilities, authorities, and accountabilities; are documented, and provide for adequate resources to implement Responsible Care.

A Responsible Care Management Systems Verification was conducted at the Sartomer corporate headquarters on April 24, 1998.

The team found a number of strengths at Sartomer relative to health, safety, and environmental management systems.

1. There is a strong management commitment, starting from the top, to environmental, health, and safety issues at Sartomer. Managers are directly involved in the implementation of EH&S programs and actively solicit employee feedback.
2. There is an organizational commitment to Responsible Care implementation. Implementation "Code Teams" that involve hourly employees and company management promote this philosophy.
3. There is a high level of Responsible Care awareness at all levels. Employees are aware of Responsible Care, and practice the ethic of the codes within their jobs.
4. Employees at Sartomer are involved in environmental, health, and safety initiatives. They participate in team meetings, benchmarking, and commercial partner education. Hourly employees and management participate in these activities.
5. There are systems in place to benchmark environmental, health, and safety activity with other companies.
6. There is a strong system for process risk assessment at Sartomer facilities. This system applies OSHA PSM standards to processes that are both inside and outside of OSHA
7. There are "gain sharing" and other related recognition programs for Sartomer employees and management related to environmental, health, and safety performance.
8. There is a strong adherence to corporate systems for commercial partner interactions at Sartomer plant locations.

1. The four performance standards for the measurement of communication and outreach programs at Sartomer are an industry best practice.
2. Sartomer’s system of product stewardship for customers and distributors is an industry best practice. The system includes partnership with customers and a "see through" relationship with customers of distributors.
3. The company emergency response plan has details for community recovery needs. Plans include financial and sheltering considerations. This level of consideration is an industry best practice.

1. There is an opportunity to develop measurable, activity-based EH&S goals for individual employees to complement existing corporate and plant goals.
2. There is an opportunity to further develop community outreach programs to include site-specific information in community newsletters.
3. Sartomer has a CAP at its West Chester manufacturing facility. There is an opportunity to strengthen programs at smaller plant locations by participating in existing multi-company CAPs.
4. An opportunity exists to develop formal timeframes for risk assessments specific to existing products, including MSDS and regulatory reviews.
5. The company acknowledges an opportunity to further develop existing commercial partner audit systems to include formal EH&S performance tracking and review.
6. There is an opportunity to formalize existing practices and develop qualification and risk information systems for toll manufacturers and contractors.
7. An opportunity exists to extend Sartomer’s excellent training programs to include proficiency testing standards.
8. There is an opportunity to further develop corporate guidelines to include environmental, health, and safety considerations in maintenance procedures.

A Responsible Care Management Systems Verification was conducted at Sartomer’s Stratford, Connecticut plant on April 22, 1998.

The team found a number of strengths at Sartomer’s Stratford Plant relative to health, safety, and environmental management systems.

1. The Stratford plant’s monthly safety meetings are an excellent tool for the review of performance information and training opportunities pertaining to environmental, health, and safety.
2. Stratford employees are involved in communicating risk-related information to commercial partners. This system maintains a strong partnership and is in the spirit of product stewardship.
3. Employees have a high awareness of Responsible Care. Employees and management are involved in the implementation of Responsible Care programs.
4. Stratford’s management team is committed to the implementation of Responsible Care. Management is involved in community outreach and employee safety programs.
5. While none of Stratford’s processes are regulated under OSHA’s Process Safety Management (PSM) standards, the site has elected to apply these requirements to its processes.
6. Stratford’s process operating procedures include environmental, health, and safety information. The first section of each procedure specifically addresses these issues.
7. There is a high level of interaction with local emergency responders and Stratford employees.
8. Safety performance is considered in the employee performance management process.
9. The employee training system; which includes continuous education for employees, self-identified program development, and proficiency testing; is a plant strength.
10. It is a policy of the Stratford site to not ship orders to customers if trucks are determined to be unsafe.
11. The Stratford plant adheres to corporate systems for the qualification and performance tracking of its commercial partners.
12. Stratford’s system for contractor safety orientation and record keeping is a plant strength.

1. Stratford’s community newsletter is an excellent first step in community outreach and involvement. There is an opportunity to develop additional programs for community outreach in the Stratford community.
2. There is an opportunity to develop quantifiable goals for environmental, health, and safety performance, including activity-based employee responsibilities.
3. Stratford employees participate in internal EH&S benchmarking through Responsible Care Code Team involvement. There is an opportunity to develop benchmarking opportunities with other companies and to formalize internal benchmarking activity.
4. Stratford employees participate in monthly safety walkthrough audits to verify general safety and housekeeping issues. There is an opportunity to develop specific agendas for these audits to further enhance the existing system.
5. An opportunity exists to expand the existing emergency response plan to include formal considerations for community recovery needs. The corporate emergency response plan could be used as a model for this activity.
6. There is an opportunity to develop incentives for employee involvement in accident and near miss reporting. The West Chester plant has developed these systems and may provide best practice ideas in this area.
7. Stratford has developed proficiency testing systems for operator job knowledge. There is an opportunity to share these systems throughout the company.

A Responsible Care Management Systems Verification was conducted at Sartomer’s West Chester, Pennsylvania plant on April 23, 1998.

The team found a number of strengths at Sartomer’s West Chester Plant relative to health, safety, and environmental management systems.

1. There is a strong commitment by West Chester management to Responsible Care ethics and practices throughout the plant.
2. Community outreach programs, including Community Advisory Panel (CAP) involvement, newsletters, and school presentations, are well-developed and comprehensive.
3. Quantifiable, activity-based goals are established for environmental, health, and safety objectives. These goals exist for all employees from the plant manager through hourly employees.
4. There are dedicated staff members at West Chester to manage plant safety and environmental issues. They are actively involved in Responsible Care implementation.
5. Employees are involved in plant environmental, health, and safety issues. They are empowered to develop and implement EH&S initiatives.
6. West Chester is heavily involved in benchmarking activity with other companies. There are strong partnerships for the development of best practices.
7. A system is in place for the review of hazards associated with plant processes. Process Safety Management (PSM) standards are applied to processes, regardless of OSHA requirements.
8. There are well-established emergency response systems in place at the West Chester plant. These include community preparedness planning, LEPC involvement, and off-site response capability for distribution incidents.
9. Training programs at the plant are strong. Employees and contractors receive extensive training before starting work at the site.
10. The "batch packet" system of safe operating procedures is a plant strength. Procedures consider safety and environmental impacts, and make operators aware of the consequences of deviation.
11. There is an excellent system in place for the management of plant contractors. Employees are empowered to stop contractors if an unsafe act is occurring, and contractors are required to review safe operating procedures before being allowed on site.

1. Community surveys are used as a tool for the assessment of community concerns. There is an opportunity to share the results of these surveys among all plant employees.
2. While employee safety systems are a plant strength, there is an opportunity to share safety performance and program information with members of the community.
3. The West Chester plant acknowledges an opportunity to develop proficiency testing for employee training programs.
4. Plant safety meetings are typically led by management. There is an opportunity to encourage hourly employees to periodically lead these meetings to develop employee ownership of plant safety initiatives.
5. The West Chester plant has developed a system of monthly safety walkthroughs for internal auditing. There is an opportunity to develop specific agendas for these audits to enhance the existing system.
6. An opportunity exists to formalize contractor performance tracking and review, including audit protocol and regular performance assessment meetings with contractor companies.
7. There is an opportunity to train additional West Chester employees in incident investigation and root cause analysis techniques.
8. West Chester has an excellent system of defining quantifiable, activity-based goals for EH&S measures. There is an opportunity to share this practice throughout the company.

From the Community and Employees:
Community Participants in the Management Systems Verification

• "You were interested in what I had to say, and that is important to me and to the West Chester community."
• "Sartomer has come a long way in improving their community outreach. Ten years ago, I wouldn’t feel comfortable coming to your plant, but now you are open to my concerns."

• "I am very impressed with the level of housekeeping and emphasis on safety at the Sartomer plant."
• "Sartomer is the first company that came to our office to request pre-fire planning assistance."

• "I make my safety and the safety of others a priority in what I do."
• "I am involved in Responsible Care implementation. I have been a part of code teams and I am active in relaying this information to my co-workers."
• "It is important to us to know that Sartomer places an emphasis on our safety. It makes me feel better when I come in to work each day."

• "Sartomer provides us detailed risk information about their products, including MSDSs and product storage and handling information."
• "We participate in frequent dialogue with Sartomer about safety and hazard issues associated with their products."
• "In some cases, Sartomer has not been proactive about providing us risk-related product information, but always sends us this information when it is requested."

• "We are involved in a partnership with Sartomer, an it involves both companies acting more responsibly."
• "We are always looking for continuous improvement opportunities. Sartomer helps provide them, and is interested in our feedback to help improve their processes."
• "Sartomer has pushed us to develop a complaint handling system for environmental, health, and safety concerns in our processes."

• "Sartomer required us to send in an evaluation of our environmental, health, and safety programs before we started work at the plant."
• "Our employees are required to go through a safety orientation before they start the job. This applies to employees that are working long term, or just for the day."

• "We receive an abundance of risk-related information from the company. It includes MSDS and product storage and handling information."
• "If we have any questions, Sartomer has people available to answer them. We never have a concern over product safety."
• "Sartomer has reviewed the information that we provide to our customers as it pertains to their products."