Edition No. 10
Responsible Care Comes of Age in the Chemical Industry
Responsible Care is moving beyond codes of management practices to improve EHS performance and obtain more value for member companies of the American Chemistry Council (ACC). The chemical and petrochemical industries are prime examples of where Responsible Care is coming of age. The Responsible Care Management System (RCMS) is now replacing the current practice of applying six codes (e.g., community awareness and emergency response, distribution, employee health and safety, pollution prevention, process safety, and product stewardship) that have a combined total of 106 management practices. (Editor’s Note: There were six original codes, but a seventh code – Security – was added later.)
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Relevant aspects of the existing codes are folded into an RCMS that is based on benchmarked best practices of leading private sector companies, initiatives developed through the Global Environmental Management Initiative and the International Standards Organization, and requirements of national regulatory authorities.
Evolution of Responsible Care
A brief look at the chemical industry over the past 15 years illustrates the progression of Responsible Care. According to the ACC’s Responsible Care web site, www.rctoolkit.com, in 1988 only 13% of Responsible Care code practices were required by Environmental, Health, and Safety (EHS) regulations. Today, almost 80% are regulatory requirements. Also, when Responsible Care was first implemented, the means of measuring whether codes were in place was through self-evaluation, which left the process open for much interpretation. Only in 1996 did RC adopt the voluntary Management System Verification (MSV) where an outside firm would conduct evaluations. Now even this process has reached obsolescence as 107 evaluations have been completed to date but no more are scheduled according to the above-mentioned site. (Companies that completed MSV will receive no credit toward the new certification process that is emerging.)
American Chemical Council members are now turning to RCMS to replace the old codes of management practices specified by Responsible Care and to drive continual improvement in their EHS performance. As an alternative to RCMS, member companies can also implement RC 14001, which is a hybrid of ISO 14001 and RCMS and satisfies the requirements of both. ACC members may achieve ACC certification by taking either the RC 14001 path or RCMS depending on the company’s management preferences and customer requirements.
RCMS Basics
RCMS is structured similarly to ISO 14001. It consists of the following sections: policy and leadership, planning (defining risks and hazards, selecting objectives and targets), process/program development, and communication. By visiting the ACC site, you can see the technical specification for RCMS and a detailed description of how to implement accountability, performance measures, corrective actions, and a management system review.
The first reporting requirement for ACC member companies implementing RCMS was due on January 1, 2004 and was a simple yes or no answer to whether the company had a RCMS in place. A new requirement of RCMS and RC14001 is that member companies must have an independent, third-party certification of their EHS management systems. To fulfill this requirement, an audit of the company’s headquarters is required by the end of 2005. Based on a company’s total number of US facilities, an audit of a designated number of plant sites will be required by the end of 2007. In 2008, the cycle starts over again for the following three years.
If a company has between 1 and 25 sites in the US, 33% of the sites (up to a maximum of four sites) and the headquarters site will require auditing. For companies between 26 and 40 sites, a maximum of six sites plus headquarters; and for companies with 41 sites and over, eight sites and headquarters would be required.
Requirements for these independent, third-party auditors have been defined by the ACC. Third-party auditors for RCMS must be approved by one of two accreditation firms, the Registrar Accreditation Board (www.rabnet.com) or the Board of EHS Auditor Certifications (www.beac.org). At this time, only the Registrar Accreditation Board approves third-party auditors for RC14001.
For More Information
The landscape for Responsible Care and the implementation of RCMS is quickly changing. At EORM, it’s our job to stay current with these changes and help companies implement RCMS or RC14001. If you are not completely comfortable with the RCMS you have in place, EORM can offer a GAP assessment of the current status of your management system. If you need assistance in filling in those gaps, we can help in that regard, too. Also, our POI (Prioritization of Issues) can give you an internal audit snapshot of your current management systems or EHS compliance status. (Editor’s NOTE: RCMS and RC14001 both require compliance audits and management system audits – EORM can do both.)
More Information:
- Contact an EORM consultant to learn how our services will benefit your company.
- View the current issue of Priority Press.
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- Send us your comments or suggestions.