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May 26, 2003
Volume 81, Number 21
CENEAR 81 21 pp. 15-17
ISSN 0009-2347
TAKING THE NEXT STEP
The U.S. Responsible Care program takes on security and verification issues as keys to enhancing its longevity and reputation

MARC REISCH, C&EN NORTHEAST NEWS BUREAU

Responsible Care coordinators met in Miami earlier this month to go "above and beyond," in the words of American Chemistry Council (ACC) organizers, in setting new targets for the now 15-year-old industry operating ethic.

But while industry executives are certain that what they are doing is right, few people outside the industry know and appreciate the effort. The group of nearly 400 who met in Miami realize they still have a long way to go to influence public opinion positively.

GAUGE Chemical plant vulnerability assessments are now a requirement under new ACC guidelines.
At the conference, they discussed the newest mandatory tools they must all adopt. Third-party verifiers will have to certify the environmental health and safety management of all 169 ACC member companies, and new verified security measures must soon be put into place to ensure the security of chemical plant sites.

In his address to conference attendees, Dan Sanders, ACC chairman and president of ExxonMobil Chemical, challenged the audience to drive performance improvements at their companies' facilities through such things as enhancing security efforts and getting a better handle on secure transportation of products. The more seriously the industry takes its ethical obligations, such as the new security codes, the more likely legislators and others "will give credit to that performance," Sanders said. And ultimately that enhances the industry's reputation, he reasoned.

Ever since the terrorist attacks on the U.S. on Sept. 11, 2001, and the new sense of vulnerability they brought to the country as a whole, ACC has been preoccupied with security. Last June, the council added a security code to focus members on the protections they need to put in place to guard against potential terrorist attacks.

Like Sanders, Michael E. Campbell, ACC Responsible Care committee chairman and chief executive officer of Arch Chemicals, spoke frankly about the value of the security code. "Our decision to adopt the security code before being told to act by the government has already paid enormous dividends," he said. "Imagine the situation we would be in with our plant communities, customers, and with the government in the absence of the security code."

"Had we not developed the security code," said ACC President Gregori Lebedev, "I know exactly where we would be today--defensive, reactive, and engaged in a losing battle for our political survival as both Democrats and Republicans race to see who could be the first to legislate a harsh regulatory regime on the chemical industry."

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Campbell
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Lebedev
ACC PHOTOS
IN FACT, Lebedev pointed out, "in promoting responsible security legislation, we have reassured our friends in government, built new or strengthened partnerships, and provided a rational outlet for a debate that could easily have been overwhelmed by emotion." Lebedev told reporters at the conference that he thinks the new Department of Homeland Security (DHS) will ultimately enforce any plant site security legislation--not the Environmental Protection Agency.

"EPA does know us very well," Lebedev acknowledged, "but it is important that as we build our approaches to security, we are associated with elements in the government engaged in security. We continue to have a robust relationship with EPA on environmental matters."

Much of ACC's activity around Responsible Care and its programs is to counter criticisms from environmental groups such as Greenpeace. According to Terry F. Yosie, ACC vice president of Responsible Care, "If we do our job well and we get external verification, we can control our own destiny."

In the area of security, that has already begun. Ira Stern, director of vulnerability assessment at DHS, told the meeting that "EPA has turned over security vulnerability assessments to us. That has been settled by the secretaries of the two agencies." DHS will assess plants on a "critical list"; it has already assessed one plant and plans to review another six to eight over the next few months.

Stern, a former U.S. marine, said DHS engages Department of Energy labs and contractors to conduct vulnerability assessments at plants. "Our experts are experienced 'breachers,' " he said. They can provide good advice on "ways to close your vulnerabilities or mask them at reasonable cost." And, he emphasized, the agency is not conducting the assessment "to embarrass you."

The company plant official working with DHS assessors has to get Secret Service clearance, Stern explained. The assessment itself requires a one- to three-day site visit. "When we leave, you guys will know what is wrong," Stern said. He promised that "reports will be available to you at local Secret Service or FBI offices." They will generally be 15 to 20 pages long and allow DHS officials to quickly review a plant's vulnerability, its defenses, and the potential impact of an attack on people and the economy.

James F. Telesh, director of corporate safety and investigation at HMHTTC Response, which trains and fields responders to environmental accidents, warned that "terrorists have infiltrated society" by coming to the U.S. to attend universities and colleges. Many remain, "and they are now applying for jobs." Telesh, another former marine, said that it is therefore particularly important that "you evaluate your contractors and ask if he and his subcontractors meet your employment requirements." Those requirements should include background checks.

Speaker Robert L. French of ExxonMobil Chemical advised administrators to "map security into your management system." French said ExxonMobil's operations integrity management system includes security along with safety, health, environment, product safety, ethics, and business conduct aspects.

Ross S. Harvison, a Lyondell Chemical risk auditing manager, agreed that security is just one of many important elements comprising a company's management system. "An effective management system can drive reliability and overall operations performance," he said. "Security," he reasoned, "is just another activity. Like safety and reliability, understand what you need to accomplish and include it into your approach."

Harvison was less worried than many other attendees about the verification requirements of the new Responsible Care security code. "If you've got effective and creative implementation of your management systems, certification should be seen as secondary."

 

YET OTHERS at the conference were still grappling with security issues. They wondered how, by the end of the year, they will manage to carry out the new security code for the most vulnerable "tier one" facilities. They were also concerned about finding third-party verifiers who can assess their new measures under the latest Responsible Care requirements.

According to Daniel Roczniak, ACC implementation and performance director, the trade association is still trying to decide just who will conduct security verification. Some conference attendees said they have asked independent auditing organizations if they will conduct security verifications. However, many of those organizations fear they might have legal liabilities if they undertake such assessments.

The entire issue of verification, both for security and for Responsible Care overall, is a thorny one. While ACC has committed its member companies to the program, it is still not really clear to some members how valuable such a verification program is. ACC tossed out an earlier voluntary management systems verification program; it seemed to have little respect. Members must now submit to mandatory third-party audits.

Aside from the security inspections, which are still loosely defined, ACC now requires all members to undergo one of two types of third-party audits by the end of 2007. The first, Responsible Care 14001 certification, lays Responsible Care's health, safety, and product security requirements over ISO 14001 environmental management assessments. ACC collaborated with the U.S.'s Registrar Accreditation Board to create RC 14001. BASF's Elastocell unit in Wyandotte, Mich., received such a certification last July, and an Arch Chemicals unit will undergo an audit later this year.

Firms may also choose to undergo a Responsible Care Management Systems (RCMS) audit with independent auditors sanctioned by ACC. According to ACC's Roczniak, the council is working with the Board of Environmental, Health & Safety Auditor Certifications to set up a protocol to certify independent RCMS auditors.

Will the public accept ACC's new third-party inspection scheme? ACC's Yossie told C&EN at the conference that he thinks the audits will go over well with the public: "John Q. Citizen won't look into the audit reports. However, he wants to be assured there is some accountability. So if someone credible and informed does the audit, that is all right."

 


The goal of Responsible Care is to "create a better, safer, and healthier world" with the new security code and verification systems contributing to that effort.


AND THOSE AUDITS will do the job because, according to Yossie, "they will meet professional standards. Auditors will be attached to ISO or other standards organizations." Yossie said he thinks the assessments will yield dividends in the long run. For companies and employees, the audits will expose areas that need improvement, and the public will get a measure of assurance. But there is, he admitted, "no single magic bullet to getting credibility with the public."

The Canadian Chemical Producers' Association has required mandatory verification of the Responsible Care ethic since 1993, and its experience has been very different, according to Brian R. Wastle, vice president of Responsible Care at CCPA. The International Organization for Standardization and its ISO management standards, he says, have no credibility with labor unions, environmental activist groups, or even with parliamentary leaders.

The question that verification has to answer is, "Is this a decent company doing the right thing?" Wastle said. In the Canadian inspection scheme, four verifiers must reach a consensus over the company's success in meeting its Responsible Care obligations. Of the two public verifiers doing the inspection, one is from CCPA's national advisory panel and one is from the local community where a facility is being inspected. The other two verifiers are from industry: One may be a retired chemical industry executive and the other a retired Responsible Care coordinator.

By contrast, ACC's new verification programs pointedly do not include industry representatives because they are meant to be true third-party inspections. Public representatives may observe the process and may be invited to comment, ACC officials pointed out, but they are not essential players in the inspection.

Wastle grants that ACC's approach may be right for its members, but said CCPA has decided to stick with its own approach. "We originally thought verification was for credibility," he said. "But now we understand that the main reason for the exercise is to help companies get better at the Responsible Care ethic."

Canadian verification is not just a pass-fail exercise as is the case with the new ACC verification protocols, Wastle said. "Verifiers won't sign off unless they find that company employees embrace the Responsible Care ethic."

In contrast, ACC's audits do not require employees to specifically embrace an ethic. What the audits do is verify the existence of a management system--a type of ongoing self-correcting management loop--to ensure employees take actions to comply with Responsible Care's ethical requirements.

One CCPA member still has not achieved Responsible Care verification after three visits. "Their management systems are fine, and they have no environmental problems," Wastle said. But verifiers have insisted on going back to look for a fourth time because so far, "the ethic has not been there," he said.

Brad Verrico, president of Verrico Associates, Newark, Del., says the old ACC Responsible Care systems verification program was a peer-based review and as such was a good first step for the industry as it got accustomed to Responsible Care audits. Independent third-party audits are the logical next step, he says.

While Verrico Associates facilitated many of the older verification audits, Verrico himself acknowledges that they are ready to be retired, and he isn't unhappy to see them go. He has helped ACC design the new verification protocols. Under ACC sanction, he has also trained ISO auditors to conduct the new RC 14001 inspections.

In addition, Verrico has joined with ENSR International, an environmental consulting organization, to advise companies on how they can develop, plan, and put in place an RC 14001 management system. "We'll do gap analysis, help write procedures, and train internal auditors," says Thomas A. Kowalski, a senior program manager with ENSR. Such full-service advice can cost from $20,000 for a smaller facility to $100,000 for a very large complex. An RC 14001 audit might cost about $20,000 per facility, says Kowalski.

The goal of Responsible Care, said Arch's Campbell, is to "create a better, safer, and healthier world." The new security code and verification systems are meant to contribute to that effort. And the broader inspections under either RC 14001 or RCMS are meant to assure the U.S. public that the industry really does not want to continue to do business the old way--behind a veil of corporate secrecy.

TAKING THE NEXT STEP
The U.S. Responsible Care program takes on security and verification issues as keys to enhancing its longevity and reputation

TELL ME--AND PROVE IT
European chemical industry looks back at Responsible Care and forward to verification



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COVER STORY
RESPONSIBLE CARE
TAKING THE NEXT STEP
The U.S. Responsible Care program takes on security and verification issues as keys to enhancing its longevity and reputation

TELL ME--AND PROVE IT
European chemical industry looks back at Responsible Care and forward to verification

Related Stories
Responsible Care Under Review
[C&EN, May 12, 2003]

Raising The Bar
[C&EN, Jun. 17, 2002]

Securing Our Chemical Plants
[C&EN, Feb. 3, 2003]

Simply Safer
[C&EN, Feb. 3, 2003]

Dramatic Changes And Challengees
[C&EN, Oct. 7, 2002]

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