Chemical Week Magazine :: Cover Story

Refocusing Responsible Care

2:49 PM EST | December 14, 2009 | Kara Sissell

External pressures are transforming Responsible Care, and trade groups are refocusing their programs to keep ahead of evolving global and domestic policy challenges. As part of that trend, ACC has kicked off a full-scale strategic review and overhaul of Responsible Care, and Canada is preparing to test out its new program, centered on sustainability, at four volunteer companies early next year.

Responsible Care program managers are working on a slate of different initiatives to make sure programs keep pace with changing external pressures, which include new regulations, public dialogue and credibility concerns, as well as the bid in the U.S. and abroad to bring more small- and medium-sized enterprises (SMEs) into the program. ACC recently announced plans for an aggressive outreach, regional training, and mentoring programs to help attract smaller firms (p. 21). Meanwhile, the Gulf Petrochemicals and Chemicals Association (GPCA; Dubai) has announced its plans to adopt Responsible Care, the result of international efforts to bring more countries and regions into the program.

Babe: Assuming a new leadership role.

Acker: Focus on green chemistry.

Phillips: Updating U.S. priorities.

Wastle: Test driving a brand new program.

In the U.S., the Responsible Care program will undergo changes to make sure it keeps pace with member and stakeholder priorities. ACC has also named Bayer Corp. president and CEO Greg Babe to serve as executive chair of ACC’s Responsible Care board committee. Babe will succeed Oxy Chem CEO Chuck Anderson on January 1 and serve for three years.

As part of its review, ACC has convened an independent, outside advisory panel that will consider a set of policy questions, and is scheduled to deliver its findings in the beginning of 2011.

A parallel effort, beginning in June, will be the responsibility of ACC’s executive task force, which will work out industry priorities and be ready to take up program changes when the advisory council releases its recommendations.

The questions ACC will pose to its advisory council—which includes experts from diverse backgrounds including nongovernmental organizations (NGOs), academia, and industry—are meant to gauge how effective the program is and where it can be improved to more adequately answer concerns that outside stakeholders may have, says Debra Phillips, ACC’s managing director/Responsible Care.

The regulatory and public opinion environment driving the full-scale review of Responsible Care is similar to pressures the industry saw after the September 11, 2001 terror attacks, which turned the spotlight on chemical plant security, Phillips says. “That made us look at the program to see what we could do it get ahead of public concerns, and what can we do to respond in a more constructive way.”

The advice ACC will ask of its outside council includes ways the chemical industry can assure that performance is improving, not only for the industry general but also for individual companies. Advisors will also be asked to look at ACC’s guiding principles and weigh in on whether there is something that can be done to update those, Phillips says. Also, ACC program managers want to know if there are areas of performance that are not currently part of Responsible Care but may need to be included. “What about energy use and what about other resource issues that are more closely tied to sustainability?” Phillips says.

Another query is whether there are different areas that Responsible Care needs to more fully include. “We do things that are connected to global warming. ACC has been requiring that energy consumption data be reported, but the program does not explicitly require that companies manage carbon issues.”

ACC also has some broad questions for the advisory council involving communications and dialogue, including public outreach issues related to overhaul of the Toxics Substance Control Act and other chemicals management concerns. ACC would also like input on how Responsible Care can be a positive conduit for those discussions and help facilitate dialogue, Phillips says.

ACC also will ask the council to weigh in on questions related to the credibility and the perception with outsiders. That will help managers gauge if the program is focusing on issues that matter most to outsiders and not just those that industry thinks matter, Phillips says.

Meanwhile, the Canadian Chemical Producers Association (CCPA; Ontario) is preparing to test drive its own overhaul of Responsible Care. The group also will change its name to the Chemistry Industry Association of Canada, effective January 1, as part of an effort to attract firms that are not producers but may export into Canada or work in a field related to chemistry.

CCPA has rewritten the Responsible Care program codes to focus on sustainability. Mock verifications at four volunteer companies will help CCPA gauge what works and what needs changing. “We’ll simply have a team of verifiers go in and start kicking tires,” says CCPA v.p./Responsible Care Brian Wastle. CCPA plans to incorporate the results of the beta tests into the program, and have the new program signed off on by the board, by June of 2010, he adds.

CCPA, which was first association to implement Responsible Care, does not intend for its revised program to serve as a template for other associations, however, Wastle says.

“We do not have a strong regulatory backdrop in Canada so we need the codes. In the U.S., they did away with the codes because regulations had caught up with the codes.” At that time, ACC had determined that compliance with regulations meant a company was in compliance with 85% of the Responsible Care codes. When CCPA did the same measurement, it discovered regulatory compliance translated into 0% compliance with the codes because the industry just is not regulated in Canada the way it is in the U.S. and elsewhere, Wastle says. “We have no process safety regulations.”

Of the nations involved in the 53 associations which have Responsible Care, Canada and the U.S. are probably the most dissimilar in terms of the legal and regulatory requisites the industry associations face. Canada’s structure is more like Chile’s or New Zealand, Wastle says.

More important to CCPA, is that its new codes for Responsible Care resonate with the type of members it is aiming to recruit, and the change has already yielded one new member, Wastle says.

CCPA’s focus on recruiting non-producer members means it will take up different advocacy issues. For example, CCPA did not assign staff to deal with Canadian regulators’ announcement that it would regulate bisphenol A (BPA) because none of its members produced BPA. Now, with a focus on recruiting members who either sell into Canada or who are non-producers linked to industry, the CCPA would respond differently now, Wastle says.

In Europe, where there is “an abundance of approaches” to Responsible Care, many nations are not as far along as the U.S. in terms of third-party certification requirements, says Cefic Responsible Care manager Bernhard Thier. Cefic, with cooperation from ACC, will mentor the GPCA in its Responsible Care efforts by helping executives get up to speed on meeting the requirements of the Responsible Care global charter.

Cefic has also been working to encourage more SMEs to join Responsible Care, acting within a program sponsored by the European Commission which promotes corporate social responsibility.

Cefic also works with member associations to help them ensure their programs keep pace with new regulations, including concerns that Responsible Care reporting requirements and the new EU pollution registry are compatible.

Cefic also focuses on fostering dialogue with European trade unions, and that cooperation has yielded significant benefits, including when trade unions backed industry positions on controversial subjects including the EU’s Registration, Evaluation, and Authorisation of Chemicals (Reach) program, and Europe’s Emissions Trading System (ETS), Thier says. That collaboration works both ways, with Cefic helping organize health workplace campaigns and conducting risk assessments of workplace safety, he adds.

It is as yet unclear if Cefic’s collaboration with trade unions would work for ACC, and the U.S. so far has not said it would go forward with a similar initiative.

The global charter requires Responsible Care programs to work toward some form of third-party certification, and again EU countries have a diverse approach. Italy will start up a third-party certification requirement for facilities at the end of 2010. However, in Germany and The Netherlands industry groups have opted to instead certify their metrics and reporting data, rather than their facilities, Thier says.

Socma, which discontinued Responsible Care in 2005 and started its own program, ChemStewards, will focus on incorporating green chemistry issues into its performance metrics and into ChemStewards in general, says Socma president Joe Acker.

Part of Socma’s focus on green chemistry stems from public opinion, but also from member firms who say they are already conducting operations that align with green chemistry’s mandate, and would like to have a way to demonstrate that to customers and the public, says Holland Jordan, Socma director/performance and business development.

Socma also says it has upgraded the ChemAlliance Web site which it bought from EPA earlier this year. ChemAlliance is an online environment, health, safety and security compliance assistance center for chemical manufacturers, distributors, and processors.

As Responsible Care broadens its reach and fine tunes its priorities, new issues are sure to emerge to test the program’s value, and its proven adaptability is what makes it work in different cultures and in the face of diverse public priorities, managers say.

For GPCA, discussion early on will have to focus on who the industry’s stakeholders are, since many facilities are not in or close to populated areas. “This will be a really interesting element for GPCA, it starts with being open to your own competitors in your industry,” Thier says. They will also have to decide who else is part of their stakeholder universe to determine what kinds of people constitute the public and who will be the target of the required stakeholder dialogue, he adds. But executives also say the program has been designed to accommodate diverse cultures and priorities.

“Responsible Care never would have lasted 25 years if it were a ‘one-size fits all’ approach,” Wastle says.

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