Responsible Care - Guide Lines
Posted On : 28th May 2009

About these Guidelines

Responsible Care® programme, originally initiated by the Canadian Chemical Producers Association (CCPA) has now been adopted by the most of the developed and developing nations. The programme rests upon the two major fundamentals. It is necessary to look beyond the law to prevent all the accidents, and the Second and the foremost is that the society has certain expectations from the chemical industry as a Corporate Citizen. The concern for the society has to be paramount in the entire gamut of SHE management.

The booklet "Responsible Care®; A Public Commitment, published by the Indian Chemical Council, is being followed as a guide for the programme by all the signatories, since the adoption of this programme by ICC since 1993.

The present guidelines are not to supplant those given in this booklet; but to supplement them. CCPA at the earlier stages of the programme thought that the prescriptive approach of suggesting all and sundries may not go well with the spirit of this programme. It was expected that the managements of such plants are well aware about the required compliance, as to what exactly is expected, and what is to be done. Perhaps this was an idealistic presumption. As is seen subsequently almost all associations and later even the CCPA itself came out with exhaustive guidelines. The present guidelines are derived from some such, no way overlooking the context. These days many a training programmes are being organised in the developed world, to guide regarding the compliances expected. There are training courses even for the auditors under Responsible Care®.

At present there are 79 signatories to the programme. It is now ripe time that the action is initiated for helping them in compliance as well as assessing the level of compliance these signatories. With the experience of theses many years, behind all of us, at Indian Chemical Council, it was felt that there perhaps exists a need for specific guidelines for certain items. Attempt here is to bridge the gap to an extent, and help the auditor and the compliant. These are expected to deliver not only a better, but a faster compliance.

Declaration of an award by the Aditya Birla Group, to the best compliant, under Responsible Care®, has given much needed boost to this programme. Already some of the signatories have communicated their willingness for getting audited, either as a requirement for obtaining the Responsible Care® logo, or for competing for the award. Modalities for these awards are under the active consideration of the association and very soon it will come out with the specifics.

These item-wise guidelines are about following first four codes only.

  1. PROCESS SAFETY
  2. EMPLOYEE HEALTH AND SAFETY
  3. POLLUTION PREVENTION
  4. EMERGENCY RESPONSE

These guidelines are to be seen as an attempt to fill the gap. However these are mere and just guidelines and should not deter any, from thinking and performing more and better. To that extent, it is an open proposition and all are welcome to give the suggestions, to improve them.

V G Bukkawar
Advisor, Safety health & Environment
Indian Chemical Council

PROCESS SAFETY - CODE OF MANAGEMENT PRACTICES
Management Practices
Management Leadership
1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance. Expects a written down document of Policies and applicable SHE standards. Top, along with the Line management has to demonstrate leadership in, and commitment to, SHE. Member Company is expected have in place, an appropriate organisation, responsibilities, authority, resources, support services and other arrangements, required to implement SHE Policy and Standards. Employee and other records shall be maintained in a retrievable form. The SHE implications of changes to organisation and activity shall be assessed. Such changes shall not compromise, and where possible, shall improve SHE performance.
2. Clear accountability for performance against specific goals for continuous improvement. Line management shall review SHE performance. Programmes to deliver continuous improvement of performance towards defined goals shall be established and monitored. Reviews shall take into account the outcome from audits and risk-assessments, and learning from incidents.
For example regarding accident prevention, decide the target and identify the areas to be tackled. Accordingly plan for supervision, training, auditing, introducing the incentives, and improving or changing work practices/procedures. Wherever necessary review standards, improve the maintenance practices and procedures.
Ensure the commitment at highest levels and also from staff, workers, trade union and contractors.
3. Measurement of performance, audits for compliance and implementation of corrective actions. For all the departments and activities on the site; record and report SHE performance, in line with the policy and standards. Incidents and complaints are to be investigated, recorded and action taken to prevent recurrence. Learning shall be shared across the entire cross-section. Enquire even about all the near-miss incidents having potential for damage.
Formal auditing and assurance procedures shall be defined and implemented to ensure that the systems and behaviours' adopted to meet these Standards are soundly established, maintained and observed. Deficiencies identified and opportunities for improvement shall be recorded and actions implemented.
4. Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in a fire, explosion or accidental chemical release. See 2 & 3 above.
5. Sharing of the relevant safety knowledge and lessons learned from such incidents with industry, government and the community. Establishment and collective use of systems and mechanisms such as MARG ( Mutual Aid & Response Group), Local Crisis Group or any other informal mechanism for sharing the lessons from. Within the factory, it could be a duly constituted and properly functioning Safety Committee, in agreement with the letter as well as the spirit of the law. The mechanisms so established should be valid for trade unions, factories in the neighbourhood and also the community around. List of the targeted stakeholders can include opinion makers in the society such as neighbouring Housing society Chairman/Secretary, Doctors, Bhajan Mandals (List is infinite. One can include Municipal Councillors, Panchayat Members and Sarpanch, School teachers etc), over and above the statutory agencies such as Local and District Crisis Groups, off-site agencies, authorities, etc. Organising meetings/trainings/site tours specifically catering to these audience groups would be of a great help while complying this issue.
6. Use of the Emergency Response process to ensure that public comments and concerns are considered in design and implementation of the facility's process safety systems. The concern for the neighbouring community should reflect in the safety, risk reduction related activities and emergency planning.
Technology
7. Current, complete documentation of process design and operating parameters and procedures.
8. Current, complete documentation of information relating to the hazards of materials and process technology. The documentation under Item 7 above should include the necessary information on the hazards of the substances stored, handled, used, processed and manufactured along with the safety related aspects of the technology.
9. Periodic assessment and documentation of process hazards and implementation of actions to minimize risks associated with chemical operations, including the possibility of human error. Depending upon the past performance, technology, plant and chemistry related specifics a schedule is to be evolved for such an assessment. This will include the periodicity and justification for the same. To have a broad judgement about a hazard as to whether it is moderate or higher an assessment is to be made using the Dow or Mond index. If the index shows that the hazard is moderate or higher, then it is to be subjected to a further review that includes detailed examination of critical process systems, plant and equipment, by using typical and appropriate Hazard Evaluation Techniques those are HAZOP study, What If Analysis, Failure Mode and Effect Analysis, Fault Tree Analysis, Event tree Analysis, Human Reliability Analysis and Risk Analysis . The depth of the approach will be governed by the rank and severity of the consequences of the hazard.
Any major deficiencies to be corrected by equipment modification where practical. Safe limits to be established for all appropriate parameters and a combination of engineering/supervisory systems to be put into place to control operation of processes, within those limits.
However consequences analysis giving damage distance for fire, explosion, toxic release and spillage involving hazardous substances will be necessary to know the damage zones, and their severity and type. Additionally the consequences foot print on a real time basis will be necessary for conducting the mock drills in realistic manner. It is also a requirement for compliance of item nos. 1 to 5 of subgroup Emergency Response under Emergency Response Code.
Written procedures to be updated and expanded to the point where all critical hazards can be properly controlled during normal and abnormal conditions, including emergencies, and systems have to be established for control of maintenance and minor modifications not covered by the capital project review process. Skill requirements to be established for all operating personnel including maintenance staff, and training to be provided to ensure that a qualified minimum human resource pool exists for each operation regardless of vacations, absence, etc. Responsibilities to be assigned to ensure that these standards are met, any exceptions being documented along with the requiring written authorization.
10. Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility. Any modifications to facilities and the arrangements for operation, Including changes to personnel, shall not compromise, and where reasonably practicable, shall improve SHE performance. Proposals for changes shall be documented and assessed, and modifications shall be authorised. Necessary hazard studies and risk assessments shall be carried out, appropriate design considerations made and all changes properly implemented and recorded. Management of change is to be interpreted as any change in hardware or software (including the change in composition of contingent manpower involved in various manufacturing operations. For e.g. a change of an operating person, who is not properly trained/acquainted, has to be treated as a change). Changing the quality related norms or even a supplier of a raw material needs to be treated as a change.
Facilities
11. Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment, and employees. For new sites or expansions or changes in old sites, it is expected that a due consideration is given to the concerns of the local community and employees, while selecting a particular technology, or a site or even a layout or equipment, over and above the applicable legal requirements.
12. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards. A mention in the policy regarding the design, construction and maintenance practices and a statement that the management is adhering to sound engineering practice and recognized codes and standards is necessary. This has to be evident in day-to-day operation and the necessary documentation confirming the same would be necessary. The justification for the choice of these codes and standards would be in line.
13. Safety reviews on all new and modified facilities during design and prior to start-up. This is in conjunction to Item No.10 and the same is equally applicable at the design and start up stage.
14. Documented maintenance and inspection programs that ensure facility integrity. Over and above legal requirements it is expected that the maintenance schedules are decided on the basis of hazard and risk. The suitable documentation is expected to be in place for these activities. Site shall be equipped, maintained and managed, so far as is reasonably practicable, to ensure continued safe and secure operation, the health of the people, the effective protection of assets and to prevent adverse environmental impact. There shall be operating procedures, pre start-up checks and routine Inspections of plant, equipment and buildings and structures of engineering construction, in the premises, to ensure their fitness for the purpose, in accordance with relevant Standards, Codes of Practices and Guidelines decided. These checks and inspections shall take into account engineering integrity, containment of materials, fire protection systems and other measures, so that there is continued conformation with controls and reduction of risks so far as is reasonably practicable. Appropriate records relating to equipment, plant or facilities and their processes shall be maintained.
15. Sufficient layers of protection through technology, facilities and employees to prevent escalation from a single failure to a catastrophic event. More the layers of protection, lesser the probability of any or for that matter catastrophic event. Some of these could be Inter-locks, Pressure Releasing System, Inter distances, Baffle Wall, etc. Depth of the approach and their Multiplicity would be in proportion to Hazard Potential and risk/s involved. A Proper Risk Analysis as suggested at S. N. 9 above would be necessary to justify the layers of protection provided.
16. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions. Indicate the provisions made in hardware for Isolation/Safe shutdowns, for those emergencies those are likely to be triggered by natural events like flood/earthquake or domino considerations etc. Also obviously expected provisions are those made for situations of failure of electricity or any other critical utilities.
Personnel
17. Identification of the skills and knowledge necessary to perform each job. The SHE behaviour expected shall be defined. SHE competencies and expertise shall be taken into consideration in the selection and placement of all personnel. The accountabilities of all employees for SHE performance shall be established. Training needs shall be identified and satisfied to ensure that all employees have the necessary skills and awareness to behave with proper regard for risks, safety and the protection of the health of themselves, others and the environment. Training and validation arrangements shall be regularly reviewed. They shall be conversant with the MSDS of substance and also the use of PPEs. There shall be regular consultation, communication and dialogue with employees on SHE matters. Employees shall be encouraged to participate in improvement programmes.
18. Establishment of procedures and work practices for safe operating and maintenance activities. Standard Operating Practices, often called as Safe Operating Procedures are to be formulated and followed. Permit to work system for all maintenance and other non-regular activities is expected to be in place.
19. Training for all employees to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job. Please see Item No.17.
20. Demonstrations and documentation of skill proficiency prior to assignment to independent work and periodically thereafter. As above.
21. Programs designed to assure that employees in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse. Integration of activities discussed in Item No.17 along with monitoring of the health of workers, for Chronic And Acute Problems is a requirement under this programme. It is also expected that suitable administrative measures are taken to prevent the drug and alcohol abuse.
22. Provisions that contractors either have programs for their own employees consistent with applicable sections of this Code or be included in the member company's program, or some combination of the two. The programme does not expect any distinction to be made between a direct employee and a employee of a contractor. It is expected that either the principle employer or the contractor ensures SHE aspects under this code.


EMPLOYEE HEALTH AND SAFETY - CODE OF MANAGEMENT PRACTICES
Management Practices
1. Commitment by all levels of management to protecting and promoting the health and safety of people working at or visiting member company sites, through published policies; accountability for implementation; and provision of sufficient resources, Including qualified health and safety personnel. See Item No.1 of Process Safety Code.
2. Opportunities for employees to participate in developing, implementing, and reviewing health and safety programs. Over and above the Safety Committee; under the Factories Act; it is expected that workers as well as unions participation is ensured in developing and implementing the SHE programmes.
3. Provisions, including selection criteria, to confirm that on-site contractors' programs are consistent with applicable Management Practices of this Code. See Item No. 22 of the Process Safety Code. An agreement or an order to a contractor to indicate that he has understood the requirements of Responsible Care Code, and has provided systems in place to ensure the same; would be necessary, along with a monitoring mechanism.
4. Written, up-to-date health and safety programs and procedures appropriate to the facility. See Item No.1 of Process Safety Code.
5. Means to verify that health and safety programs and procedures are effective and that actual practices are consistent with these programs. A verification and follow up mechanism is to be established by identifying the persons in the line management, responsible for such a monitoring, to check the adherence to the code.
6. Systems for maintaining records and analyzing data to evaluate health and safety performance determine trends and identify areas for improvement. Maintaining the records and Reviewing & Analyzing the data so generated, and corresponding corrective action wherever and whenever necessary.
7. Methods to identify and evaluate potential health and safety hazards in planned or existing facilities, including facilities to be notified. See Item No.9, 11, 14 &15 of Process Safety Code.
8. Exposure assessments and safety analysis to evaluate health and safety hazards to employees from processes; equipment; potentially hazardous chemical, physical, or biological agents or other work site conditions Work-place, air quality monitoring is a requirement under this item, so as to evaluate short term and long term hazards to the employees. Based upon the results of such a study, suitable changes in either the plant and machinery or the work procedures are expected.
9. Health assessments to determine employee medical fitness for specific job tasks. While considering the issues raised by item No 17 of Process Safety Code, also give consideration to health assessment and the medical fitness.
10. Employee occupational medical surveillance programs tailored to work site hazards. See Item No.8 above.
11. Mechanisms for reviewing the design and modification of facilities and job tasks, taking into account the following hierarchy of controls: inherent safe design, material substitution, engineering controls, administrative controls, and personal protective equipment. See Item No.14 of Process Safety Code.
12. Systems to verify that health and safety equipment is properly selected, maintained and used. A review and auditing mechanism right from the stage of floating an enquiry for purchasing together with the preventive, as well as regular maintenance programme would be necessary.
13. Preventive maintenance and housekeeping programs to maintain the safety of facilities, tools and equipment. See Item No.14 of Process Safety Code.
14. Timely investigation of work site illnesses, injuries, and incidents; corrective actions to prevent recurrence; and evaluation of the effectiveness of corrective actions taken. Occupational Health related monitoring with the competent person/s has to be in place.
15. Security procedures and systems to control entry and exit of personnel and materials at the work site and restricted areas.
16. Provisions for emergency medical assistance for people at work sites. Over and above the statutory provisions and the medical facilities provided otherwise; it will be necessary, that a certain percentage of employees are trained in First Aid and also it is ensured that such trained minimum contingent is always available.
17. Communication of health and safety information that is relevant to specific job tasks and the work site. Training specific to the job is expected to include such information. A tool like job safety analysis can be used.
18. Health and safety, training programs, including documentation of these programs, and methods to evaluate the effectiveness of both training and communications activities.


POLLUTION PREVENTION - CODE OF MANAGEMENT PRACTICES
Management Practices
1. A clear commitment by senior management through policy, communications, and resources, to ongoing reductions at each of the company's facilities, in releases to the air, water, and land and in the generation of wastes. See Item No.1 of Process Safety Code.
2. A quantitative inventory at each facility of wastes generated and releases to the air, water and land, measured or estimated at the point of generation or release. Over and above the Safety Committee; under the Factories Act; it is expected that workers as well as unions participation is ensured in developing and implementing the SHE programmes.
3. Evaluation, sufficient to assist in establishing reduction priorities, of the potential impact of releases on the environment and the health and safety of employees and the public. A review at a certain periodicity is expected to assess the possibility of reduction in pollution load. A consideration for employee's health and safety would be a part of such a review.
4. Education of and dialogue with employees and members of the public about the inventory, impact evaluation, risks to the community. Discussed in Emergency Response Code.
5. Establishment of priorities, goals and plans for waste and release reduction, taking into account community concerns and the potential health, safety, and environmental impacts as determined under Practices 3 and 4. See Item No.5, 6 & 11 of the Process Safety Code.
6. Ongoing reduction of wastes and releases, giving preference first to source reduction, second to recycle/reuse, and third to treatment. These techniques may be used separately or in combination with: one another.
7. Measurement of progress at each facility to reducing the generation of wastes and in reducing releases to the air, water, and land, by updating the quantitative inventory at least annually.
8. Ongoing dialogue with employees and members the public regarding waste and release information, progress in achieving reductions and future plans. This dialogue should be at a per 1al, face-to-face level, where possible and should emphasize listening to others and discussing their 1cerns and ideas.
9. Inclusion of waste and release prevention objectives in research, and to design of new or modified facilities, processes, and products. While considering the issues raised by item No 17 of Process Safety Code, also give consideration to health assessment and the medical fitness.
10. An ongoing program for promotion and support waste and release reduction by others, which may, for example, include: Sharing of technical information and experience with customers and suppliers.
a) Support of efforts to develop improved waste and release reduction techniques.
b) Assisting in establishment of regional air monitoring networks.
c) Participation in efforts to develop consensus approaches to the evaluation for environmental, health and safety impacts of releases.
d)Providing educational workshops and training materials
d) Assisting local governments and others in establishment of waste reduction programs benefiting the general public.

11. Periodic evaluation of waste management practices associated with operations and equipment at each member company facility, taking into account community concerns and health, safety and environmental impacts and implementation of, ongoing Improvements See Item No.5, 6 & 11 of the Process Safety Code.
12. Implementation of a process for selecting, retaining and reviewing contractors and contract: manufacturers taking into account sound waste management practices that protect the environment and the health and safety of employees and the public. It is expected that the contractor selection criteria, satisfies the requirement of Responsible Care Programme and concerns therein regarding Environment, Safety and Health. The guidelines pertaining to contractor mentioned earlier are equally applicable.
13. Implementation of engineering and operating controls at each member company facility to improve prevention and early detection of' releases that may contaminate groundwater. See Item No.14 of Process Safety Code.
14. Implementation of an ongoing program for addressing past operating and waste management practices and for working with others to resolve identified problems at each active or inactive facility owned by a member company, taking into account community concerns and health, safety, and environmental impacts. Mention the efforts and inputs pertaining to tackling the problems of environment on a common forum which may include activities such as Common Effluent Treatment Plant, Common Land Fill Sites etc.


EMERGENCY RESPONSE - CODE OF MANAGEMENT PRACTICE
Management Practices
1. An ongoing assessment of employee concerns and questions about the facility. Efforts are to be made to educate the employees for hazards and their safe management. Training and the refresher courses, to educate and prepare the workers, as a responder for tackling the likely emergencies, is necessary.
2. Communications training for key facility and company personnel who will communicate with employees and the public concerning safety, health, and environmental issues. Identification and provision of responders engaged in key functions, communicating for and during the emergencies. Establishing a regular channel of interaction with the community around and also putting up the specific responsibility on line managers and creating an organizational base and systems for the same is another requirement.
3. Education of employees about the facility's emergency response plan and safety, health and environmental programs. A specific training based upon the response related tasks that include the necessary information about hazard and environmental impact.
4. An ongoing dialogue with employees to respond to their questions and concerns. A two way dialogue is necessary between the planning and execution teams, to make the planning comprehensive and realistic.
5. A regular evaluation of the effectiveness of the ongoing employee communications efforts. A properly organised and conducted mock-drill with a review at the conclusion of such a mock-drill, is the requirement.
6. An ongoing assessment of community questions and concerns about the facility. See Item No.2 above. Additionally monitoring mechanisms may be established.
7. Program to educate responders, government officials, the media, other businesses and the community about the facility's emergency response program and risks to the community associated with the facility. Indicate activities under MARG (Mutual Aid & Response Group), Local Crisis Group constituted under THE CHEMICAL ACCIDENTS (EMERGENCY PLANNING, PREPAREDNESS, AND RESPONSE) RULES, 1996 Also indicate the interaction with opinion makers or specific interest group such as Teachers, Doctors, etc. (See S N 5 of Sub-group Management Leadership of Process Safety Code).
8. A regular evaluation of the effectiveness of the ongoing community communications efforts. A distinction is to be made between the risk assessed and perceived. Former is a product of study and later would be impression of community around. Indicate the efforts made to reduce such apprehension in the mind of community.
Emergency Response
1. An ongoing assessment of potential risks to employees and local communities resulting from accidents or other emergencies. See Item No.9 & 15 of Process Safety Code.
2. A current, written facility emergency response plan which address, among other things, communications and the recovery needs of the community after an emergency. A periodically reviewed, updated, well circulated and frequently rehearsed On-site Emergency Plan drafted on standard guidelines should be in place.
3. An ongoing training program for those employees who have response or communications responsibilities in the event of an emergency. See Item No.2 of Communication Programme of this code above.
4. Emergency exercises, at least annually, to test operability of the written emergency response plan. Conducting and review of properly organized mock-drill, at least annually.
5. Communication of relevant and useful emergency1response planning information to the Local Emergency Planning Committee. See Item No. 7 of Communication Program of this code above.
6. Facility tours for emergency responders to pro-mote emergency preparedness and to provide current knowledge of facility operations.
7. Coordination of the written facility emergency response plan with the comprehensive community emergency response plan and other facilities. If no plan exists, the facility should initiate community efforts to create a plan.
8. Participation in the community emergency response planning process to develop and periodically test the comprehensive community emergency response plan developed by the Local Emergency Planning Committee.
9. Sharing of information and experience relating to emergency response planning, exercises, and the handling of incidents with other facilities in the community.

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