Responsible Care 14001 Management System Technical Specification Implementation Guidance

®
Responsible Care 14001

Management System
Technical Specification
Implementation Guidance
Document 2.0
Responsible Care® 14001:2002
March 2002
 American Chemistry Council 2002
ACC: Doc. 2.0 Responsible Care® 14001:2002

Implementation Guidance- March 2002
Responsible Care® 14001
Management System
Technical Specification
Introduction
®
This Guidance Document is used to support the Responsible Care 14001 Mangement
System Certification Process. This process is intended to certify companies to a
standard for Responsible Care® as measured by a third party. It should be executed in
conjunction with an ISO 14001 audit to provide joint certification for a company.
The Technical Specification and this Implementation Guidance document were created
by a team that included representatives of American Chemistry Council Member
Companies, ISO 14000 Registrars, the Registrar Accreditation Board (RAB), American
Chemistry Council staff, and environmental, health, and safety consulting firms.
Information was used from the 106 Responsible Care Codes of Management Practices,
and the American Chemistry Council Responsible Care Management Systems
®
Verification (MSV ) process.
This Guidance Document can be used by Responsible Care 14001 auditors or by

companies preparing for an audit. It addresses a number of issues that may be helpful
to both groups. These include:
• Responsible Care® 14001 Management System Technical Specification – this

document includes the wording from the Technical Specification, which is used as
an audit “protocol.” For copies of the actual Responsible Care® 14001
Management System Technical Specification with corresponding ISO 14001
language, please contact the American Chemistry Council.
• Responsible Care® Codes – while this Guidance document does not list all the
Responsible Care® Codes of Management Practices, there is a column that
provides information about how the Codes match the Technical Specification
elements. For copies of the actual Responsible Care® Codes of Management
Practices, please see Attachment 2 of this document.
• Areas to Address – these are broken into two areas of discussion:
• Potential Questions – Questions that might be asked by an auditor to
obtain needed information about each Technical Specification element.
Auditors will develop their own questions for an actual audit.
• Guidance – Based on the experience of the development team, the
Guidance section is used to provide information and direction to auditors and
those companies preparing for an audit. This can include types of objective
evidence an auditor might seek, potential pitfalls, follow up areas, potential
interviewees, appropriate documentation, etc.
• Links to Other Standards – Areas where the technical specification links to ISO
14001:1996 and the United Kingdom’s Chemical Industries Association (CIA)
Responsible Care® management system model.

Thi

DRAFT Responsible Care® 14001 Management System Certification Guidance Document
Responsible Care® Management Responsible Care® Areas to Address Links to
System Technical Specification Codes other
standards
1.1 The policy shall: In general, relevance is Potential Questions: ISO 4.2(a)
reflected in all of the UK-CIA 3.2
be relevant to the nature and scale of the codes through the Has top management defined the organization’s
organization’s products, processes and concept of “actions environmental, health and safety policy?
environmental, health and safety impacts; proportional to risks”
Is this environmental, health and safety policy appropriate to
the nature, scale and environmental, health and safety
impacts of the organization’s activities, products or services?
In the setting of environmental, health and safety policy does

the organization consider:
• Good EHS practices ?
• Business goals?
• Product Lines & Services?
• Impacts on employees and communities?
Guidance:
Ask for copies of policies. Are they posted?
Example: A chemical company that is a subsidiary of a

paper company. If the chemical company’s environmental,
health, and safety policy is related solely to sustainable
forestry, then it is not relevant to the nature of the chemical
operations.
Looking for review against peers.
1
Key: PSM – Process Safety Code CAER – Community Awareness and Emergency Response Code
EHS – Employee Health and Safety Code UK-CIA – Chemical Industries Association of the United Kingdom
PP – Pollution Prevention Code RC – RC Certification document references
PS – Product Stewardship Code EHS – Environmental, Health, and Safety
D- Distribution Code ISO – ISO-14001: 1996 Standard

Implementation Guidance March 2002
standards
1.2 set a framework for reviewing and PSM2- Clear Potential Questions: ISO 4.2 (d)
establishing Responsible Care goals, accountability for UK-CIA 2.2,
objectives, and targets; performance against Does the environmental, health and safety policy provide the 3.3
specific goals for framework for setting and reviewing of environmental
continuous improvement. objectives and targets?
PP5- Establishment of
priorities, goals and plans Have environmental, health and safety objectives and targets
for waste and release been established and documented?
reduction...
PS2- Establish goals, Has the organization considered the legal and other
responsibilities to requirements, its significant environmental, health and safety
implement Product aspects, its technological options and its financial,
Stewardship throughout operational and business requirements, and the views of
the organization … interested parties when establishing and reviewing its
objectives?
Are the objectives and targets consistent with the

organization’s environmental, health and safety policy,
including the commitment to prevention of pollution?
Have roles, responsibility and authorities been defined,

documented and communicated?
Guidance:
This is an important element of the standard for senior

management. It will create a backdrop for the same
questions asked throughout the review at different levels of
the organization.
2

standards
1.2 (continued) Guidance (continued)
Follow up questions could be:

• Are goals top down or bottom up?
• Are plant goals “activity” goals based on corporate
numeric goals? (E.g., if there is a corporate goal of
zero injuries or an injury rate of 2.0 are there plant
goals related to activities like hand safety or back
safety that would help achieve the corporate
numeric goals.)
• Are there individual activity goals to support these
plant activities and corporate metrics?
There is a subsequent element (2.3) related to maintaining

goals, objectives, and targets and keeping them current.
1.3 include a commitment to Guid Princ- We will Potential Questions: ISO 4.2(a)
continual improvement and prevention of make continuous UK-CIA 3.2
pollution. progress toward the Does the environmental, health and safety policy include a
vision of no accidents, commitment to continual improvement and prevention of
injuries or harm to the pollution?
environment…
PSM1- Leadership by Guidance:
senior management...in
achieving continuous This simply needs to be stated explicitly in the written policy
improvement of – both continual improvement and pollution prevention.
performance.
3

standards
1.3 (continued) PP1- A clear commitment

by senior
management...to ongoing
reductions at each of the
company’s facilities in
releases to the air, water,
& land, & in the
generation of wastes.
D- Adherence to the code
will lead to continually
safer chemical
distribution...
1.4 include a commitment to comply Adherence to the Codes Potential Questions: ISO 4.2 (c)
with relevant legislation and regulations of Management Practices UK-CIA 2.3
and with other requirements to which the of Responsible Care Does the Responsible Care policy include a commitment to
organization subscribes. will...help member comply with relevant environmental legislation and
companies to meet or regulations, and to other requirements to which the
exceed all regulations organization subscribes?
and industry standards
governing chemical Is there a procedure to identify and have access to legal and
distribution. other requirements that the organization subscribes, that are
applicable to the environmental, health and safety aspects of
the organization’s activities, products or services?
Guidance:
Philosophically, Responsible Care considers compliance with

4

standards
regulations to be a “given.” But here it must be explicitly
stated in the policy. The auditor must also probe for other
“agreements” or processes that the company has subscribed
to and include those in their written policy. (E.g.,
Responsible Care, CERES Principles, etc.)
1.5 reflect the company’s Guid Princ- We Potential Questions: UK-CIA 3.1,
commitment to the Guiding Principles of (Responsible Care 3.3
Responsible Care. companies) will lead our Does the policy reflect the company’s commitment to the
companies in ethical Guiding Principles of Responsible Care?
ways…while adhering to
the following principles Guidance:
This might be covered above but again needs to be explicitly

stated in the policy.
1.6 be documented, implemented, PSM 1- Leadership by Potential Questions: ISO 4.2 (e)
maintained and communicated to senior management UK-CIA 3.2
employees and made available to through... Is the environmental, health and safety policy documented,
stakeholders, including members of the communications... implemented and maintained and communicated to all
public. EHS1- Commitment by all employees?
levels of management to
protecting and promoting Is the environmental, health and safety policy available to the
the health and safety of public?
people working at or
visiting member company Have appropriate procedures been established for Internal
work sites, through: and external communications regarding the environmental,
published policies... health and safety aspects and the environmental, health and
PP1- A clear commitment safety management system, including:
by senior management
through... • Internal communication within the organization?
communications...
5

standards
D- Each member • Receiving, documenting and responding to relevant
company shall have an communication from interested external parties?
ongoing chemical
distribution safety
program that includes
senior management...
communications...
1.6 (continued) PS1- Demonstrates Guidance:
senior management
leadership Look for the written policy, revision dates, and evidence of
through...communication. communications with all stakeholders (e.g. employee and
community meeting minutes, inclusion in Annual Reports,
letters to customers, etc.)
1.7 be supported by a demonstration PSM1 – Leadership by Potential Questions: UK-CIA 2.1
of personal commitment from senior senior management
management to Responsible Care. through … participation… How do you demonstrate your personal commitment to
EHS1 – Commitment by Responsible Care? (asked to senior management
all levels of management representative)
to protecting and
promoting the health and Guidance:
safety of people working
at or visiting member This requires a demonstration of commitment from senior
company work sites, management (could be the CEO, the plant manager, or the
through: published VP of Manufacturing, etc.) to EHS and to Responsible Care.
policies; …
implementation A typical clarification question here is: How do your
PS1 – Demonstrates employees and your external stakeholders know that you are
senior management committed personally to Responsible Care?
leadership through …
active participation …
6

standards
1.8 be supported by fostering PSM1 – Leadership by Potential Questions: ISO 4.2 (f)
openness in dealing with stakeholders, senior management UK-CIA 3.2
taking into account public and employee through … participation… Is there demonstrated employee involvement in the
inputs. EHS1 – Commitment by development and modification of Responsible Care and EHS
all levels of management policies?
to protecting and
promoting the health and Is there demonstrated public involvement in the review and
safety of people working update of Responsible Care and EHS policies?
at or visiting member
company work sites, Guidance:
through: published
policies; … Look for evidence that there has been opportunity for the
implementation public and employees to have direct or indirect input into the
PS1 – Demonstrates policy development process. (e.g., during community focus
senior management groups, CAP meetings, employee meetings, committee
leadership through … reviews, etc.)
active participation …
Employee input should include a forum for “hourly” or “shop
floor” employees.
7

standards
2.1 The organization shall Guid Princ3 to make Potential Questions: ISO 4.3.1
demonstrate appropriate planning by: health, safety and the UK-CIA 4.0,
environment and Is there a system to assess risk for: 4.2, 4.3, 4.5,
having a system in place for identifying and resource conversation •New products? 7.5.1, 7.5.2
assessing environment, health, safety and critical for all new and •Existing products?
other Responsible Care® aspects, including existing products and •Changes to existing products?
hazards and risks associated with new and processes.
existing products, manufacturing ER1 An ongoing Is there a system to assess risk for:
processes, changes to existing products assessment of potential •New processes?
and processes, and transport and risks to employees & local •Existing processes?
distribution of products including creating communities resulting •Changes to existing processes?
and maintaining product information related from accidents or
to environmental, health and safety emergencies. Does the process risk assessment system go beyond those
hazards and risks. This information shall PSM9 Periodic covered by regulations?
be regularly reviewed and kept current. assessment and
documentation of process Is there a system to assess transportation risk?
hazards...
EHS7 Methods to identify Is there a system to maintain and provide product risk
and evaluate potential information?
health and safety hazards
in planned or existing Guidance:
facilities, including
facilities to be modified. General
EHS11 Mechanisms for This element tackles a number of significant issues related to
reviewing the design and risk assessment systems. This should be related to
modification of facilities... processes, products, and transportation of products. It also
addresses the system to maintain product risk information.
There is a need to distinguish between an organization’s

product and process risk assessment systems.
8

standards
2.1 (continued) PP3 Evaluation, sufficient

to assist in establishing Product Risk
reduction priorities, of the A key point here is that there is a system of risk
potential impact of assessments related to all of the company’s activities –
releases on the commensurate with the risk. It must also include a method
environment and the for informing the supply chain of product risk.
health and safety of
employees and the Look for evidence that these types of risks are evaluated
public. during the new product or process risk assessment and on
D1.1 Regular evaluations an ongoing basis.
of chemical distribution
risks which consider the Process Risk
hazards of the material, For process risk assessment, much of what a company does
the likelihood of is covered by OSHA PSM regulations, if they apply.
accidents/incidents and
the potential for human Transportation Risk
and environmental This element also addresses transportation risk assessment.
exposure from release of Some companies use commercial software for route
the material over the assessment that takes into account population centers, road
route of transport. conditions, etc.
PS4 Establishes and
maintains information on Transportation risk assessment applies if the types of
health, safety and products that the company transports are indeed hazardous.
environmental hazards If hazards are no greater than bread flour risk assessment
and reasonably for transportation is not an issue.
foreseeable exposures
from new and existing Product Information
products. Product information can be simply the MSDS and product
label, but sometimes there are product brochures and other
safe handling literature. Ask for an example of a Technical
9

standards
Bulletin, etc. that is provided to customers or distributors.
2.1 (continued) PS5- Characterizes new

and existing products with
respect to their risk using
information about health,
safety and environmental
hazards and reasonably
foreseeable exposures.
2.2 having a system in place to review D2.1 - A process for Potential Questions: ISO 4.3.2
and determine the applicability of monitoring changes and UK-CIA 4.1
environmental, health and safety interpretations of new and Is there a system to track federal, state, and local
regulations, legislation and other existing regulations and regulations?
requirements to which the organization industry standards for
subscribes; their applicability to the Are regulatory interpretations provided to appropriate
company’s chemical parties?
distribution activities, and
for the implementing Is there a system to review and update other requirements to
those regulations and which the organization subscribes?
standards. Guidance:
Look for processes for keeping track of federal, state, and

local legislation and regulations related the EHS issues. A
follow up is to ask if there are interpretations of regulations
done for operations to implement these regulations.
Regulator or legislator lobbying is not what the auditor should

look for here.
10

standards
2.3 maintaining documented PSM2- Clear Potential Questions: ISO 4.3.3
Responsible Care policy, goals, objectives, accountability for ISO 4.3.4
and targets at each relevant function and performance against Do you maintain Responsible Care and EHS goals and keep UK-CIA 5.1,
level of the organization which have clear specific goals for them current? 5.2, 6.5, UK-
means, time frames, and responsibilities continuous improvement. CIA 6.5.3
for accomplishment; PP5- Establishment of Are goals maintained at each level of the organization?
priorities, goals and plans
for waste and release Guidance:
reduction...
PS2- Establish goals, There is a previous element (1.2) related to the
responsibilities to establishment of goals, objectives, and targets.
implement Product
Stewardship throughout This element requires the company to look those goals on
the organization… some frequency, compare them to actual performance, and
make appropriate adjustments to them. Remember to focus
on Responsible Care and EHS-related goals.
2.4 having systems in place for the EHS1 - Commitments... Potential Questions: UK-CIA 4.1
identification of needs and allocation of through...provision of
resources to implement Responsible Care sufficient resources... Does management provide the resources essential to the
in order to provide for continual PP1 - A clear implementation and control of the environmental, health and
performance improvements, and commitment...through... safety management system?
compliance with relevant legislation and resources to ongoing
regulations; reductions at each of the Has the organization gone through a process to assess the
company’s facilities in adequacy of its resources related to Responsible Care
releases to the air, water, tasks?
& land, & in the
generation of wastes. Guidance:
Look for a business planning process for resource allocation

that also applies to environmental, health, and safety
resources. It may not be specific EHS professionals.
11

standards
2.4 (continued) D - Each member This is a place to evaluate whether or not the EHS function is
company shall have an integrated as part of the job functions of non-EHS
ongoing chemical professionals (E.g., the Production Superintendent might be
distribution safety responsible for implementing the Process Safety Code.)
program that
includes...resources... The focus here, regardless of the number of dedicated EHS
PS3 - Commits resources professionals versus EHS-related line functions, is has the
necessary to implement organization gone through a process to assess the adequacy
and maintain product of its resources related to Responsible Care tasks?
stewardship practices.
2.5 Senior Management appointing PSM1 - Leadership by Potential Questions: ISO 4.4.1
specific representatives for ensuring the senior management UK-CIA 6.3
effective implementation of Responsible through...resource Has top management appointed a management
Care and reporting on the performance of commitments... representative to ensure that environmental, health and
the management system; safety management system requirements are established,
implemented and maintained?
Have roles, responsibility and authorities been defined,
documented and communicated?
Does management provide the resources essential to the
implementation and control of the environmental, health and
safety management system?
Has top management appointed a management
representative to ensure that environmental, health and
safety management system requirements are established,
implemented and maintained?
Has top management appointed a management
representative to report on the performance of the
environmental, health and safety management system to top
12

standards
management for review and system improvement?
2.5 (continued) Has top management appointed a management

representative to report on the performance of the
environmental, health and safety management system to top
management for review and system improvement?
Guidance:
Same as above, with more focus on the appointment of (a)
point person(s) responsible for Responsible Care
implementation.
2.6 having systems in place to assess CA1 - An ongoing Potential Questions: ISO 4.3.3
stakeholder concerns and to ensure assessment of employee ISO 4.4.3
employee involvement in the development questions and concerns Is there a system to regularly assess employee concerns, UK-CIA 5.1,
of Responsible Care programs; about the facility. especially related to EHS and Responsible Care? 6.6.2
CA6 - An ongoing
assessment of Is there a system to regularly assess community concerns,
community questions and especially related to EHS and Responsible Care?
concerns about the
facility. Is there a system to regularly assess other stakeholder (as
PSM6 - Use of the CAER defined in the company’s Responsible Care management
process to assure public system) concerns, especially related to EHS and
comments and concerns Responsible Care?
are considered in design
and implementation of the Guidance:
facility’s process safety
systems. There will be a number of formal and informal systems for
EHS2 - Opportunities for assessment. The audit team will need to judge if these are
employees to participate adequate and do serve as a mechanism to assess
in developing, community concerns.
implementing, and
13

standards
reviewing health and
safety programs.
2.6 (continued) D5.5 - Dialogue with the Its easy for the company to say that just their everyday
public on their concerns contact with the community is an assessment process – but
about chemical look for a more formal process and one that is used to feed
distribution safety, actions into some action process.
taken by…the company
to improve the safety of There will be similar information offered here to that of a later
chemical distribution, and element (4.7) about measuring the effectiveness of
the effectiveness of communication. In this element, look for a process to assess
emergency concerns. Focus Groups, Surveys, and CAPs can do both –
preparedness... but in this case look for active processes in place to be
PP8 - Ongoing dialogue aware of concerns as they are emerging, as opposed to an
with employees and after-the-fact measurement of communications effectiveness.
members of the public
regarding waste and Remember to review the organization’s process to assess
release information, concerns for each stakeholder category, including
progress in achieving employees, community, and commercial partners.
reductions, and future
plans…emphasize
listening to others and
discussing their concerns
and ideas.
14

standards
3.1 The organization shall PSM2 - Clear Potential Questions: ISO 4.4.1
demonstrate that implementation, accountability for
operation and accountability are part of performance against Have roles, responsibility, and authorities been defined,
the Responsible Care Management specific goals for documented, and communicated?
System by establishing and continuous improvement.
maintaining: PS2 - Establishes goals Guidance:
and responsibilities for
a clear definition of responsibility and implementing product This may get into individual performance evaluations, which
accountability for the implementation of stewardship throughout is also addressed in element 5.4.
Responsible Care. Responsibilities shall the organization.
be documented and communicated to all Here look for mechanisms to let employees know that EHS
appropriate personnel. performance is part of their job. Very often this answer will
describe the Responsible Care organizational structure with
Code Stewards, etc.
Here, the focus should be the integration of EHS and

Responsible Care responsibilities and accountabilities into
everyone’s job.
Also, look for a network of Responsible Care Code

coordinators that are integrated into line organization.
3.2 training programs that include CA2 - Communications Potential Questions: ISO 4.4.2
those specific skills and competencies training for... personnel
required by the Responsible Care who communicate with Have all training needs been identified? UK-CIA 6.4,
Management System and awareness of employees and the 7.4.3, 5.5
regulatory requirements appropriate to the public... Have procedures been established and maintained to make
task. ER3 - An ongoing training employees or members of each relevant function and level
program for those aware of:
employees who have • The importance of conformance with the
response or environmental, health and safety policy and procedures
communications
15

standards
responsibilities.... and requirements of the environmental, health and
3.2 (continued) PSM17 - Identification of safety management system?
the skills and knowledge • The significant environmental, health and safety
necessary to perform impacts of their work activities and the environmental,
each job. health and safety benefits of improved personal
PSM19 - Training for all performance?
employees to reach and • Their roles and responsibilities in conformance with the
maintain proficiency in... environmental, health and safety management system,
and the skills and including emergency preparedness and response
knowledge necessary... requirements?
PSM20 - Demonstration • The potential consequences of deviation from
and documentation of operating procedures?
skill proficiency prior to
assignment to Have procedures been established to make employees or
independent work... members at each relevant function and level aware of
PSM21 -Programs environmental, health and safety issues?
designed to assure that
employees...are fit for Has it been ensured that personnel performing tasks, which
duty and are not can cause significant environmental, health and safety
compromised by external impacts, are competent?
influences, including
alcohol and drug abuse. Guidance:
EHS17 - Communication
of...information that is This element addresses training programs. Look for
relevant to specific job information on the handling of new employees, refresher
tasks and the work site. training for existing employees, testing, competency
D2.2 - Training for... requirements, etc.
employees in the proper
implementation of This does not need to refer to specific environmental, health,
applicable regulations and safety or Responsible Care training – but it can. Normal
and company training related to operating or maintenance is to avoid
16

standards
requirements. upsets, incidents, or catastrophes should also be reviewed.
3.2 (continued) PS8 - Educates and

trains employees... on the
proper handling,
recycling, use and
disposal of products and
known uses...
3.3 a process for communication, CA8 - A continuing Potential Questions: ISO 4.4.3
outreach, and dialogue with stakeholders dialogue with local
about relevant risks, and the organization’s citizens to respond to Has the organization developed a system to communicate to UK-CIA
impact on human health and the questions and concerns... all stakeholders, including employees, communities, and 6.6.1, 6.6.2
environment, and plans for improving the PSM5 - Sharing of commercial partners?
organization’s performance. relevant safety Does the communication system include processes for
knowledge and lessons stakeholder outreach and dialogue?
learned from such
incidents with industry, Do communications programs include information about
government and relevant risks and the organization’s impact on human health
community. and the environment?
PP8 - Ongoing dialogue Guidance:
with employees and
members of the public... Here, the auditor should focus specifically on the
D5.4 - Dialogue with state organization’s process to communicate with the community,
and local emergency employees, and other stakeholders. This will probably have
planning organizations... been covered a number of times in the answer to other
D5.5 - Dialogue with the outreach elements.
public...
Look for school involvement, CAPs, and employee
communication.
17

standards
3.4 employee involvement in the CA4 - An ongoing Potential Questions: UK-CIA
communication and implementation of dialogue with employees 6.6.1, 7.4.3
Responsible Care programs. to...involve them in Do employees at all levels demonstrate a knowledge of
community outreach Responsible Care?
efforts.
EHS2 - Opportunities for Are employees at all levels involved in the Responsible Care
employees to participate Management System?
in developing,
implementing and Do employees participate in the development,
reviewing health and communication, and implementation of the Responsible Care
safety programs. Management System?
Guidance:
This element addresses employee involvement in the

organization's Responsible Care management systems. It
can relate to involvement with safety programs and to
involvement with the community.
As a follow up, ask if employees are involved with

environmental issues as well as safety.
Auditors should focus on an organization’s hourly or shop

floor employee involvement in these systems.
18

standards
3.5 documented procedures PSM7 - …documentation Potential Questions: ISO 4.2 (b)
sufficient to ensure safe operations of of process design, ISO 4.3.3
processes, process changes and operating parameters and Has the organization identified those operations and ISO 4.4.6
maintenance activities and the procedures…PSM8 - activities that are associated with the identified significant
achievement of Responsible Care policy, …documentation of EHS aspects in line with its policy, objectives, and targets? UK-CIA
goals, objectives and targets, including information relating to the 7.4.2, 7.5,
emissions reduction, pollution prevention, hazards of materials and Do operating and maintenance procedures include specific 7.6.1, 7.6.2
and ground water protection programs. process references to EHS requirements, including:
technology...PSM10 - •personal protective equipment (PPE)?
Management of changes •operating limits?
to chemical •consequences of deviation?
operations...PSM12 - •emergency procedures?
Facility design, •safety or life-critical activities?
construction and
maintenance …consistent Has the organization planned operating and maintenance
with recognized codes activities in order to ensure they are carried out by:
and standards…PSM13 - •establishing and maintaining documented
Safety reviews on all new procedures for situations where their absence could
and modified lead to deviations from the EHS policy and
facilities...PSM14 - objectives and targets?
Documented •stipulating operating criteria in the procedures?
maintenance and •establishing and maintaining procedures related to
inspection the identifiable significant EHS aspects of goods and
programs...PSM15 - services used by the organization and
…layers of protection communicating the relevant procedures and
…to prevent...PSM16 - requirements to suppliers and contractors?
…control of processes
and equipment during Are there adequate systems to reduce site emissions?
emergencies...PSM18 -
Has the organization developed and implemented pollution
..procedures …for safe
prevention systems?
operating and
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standards
maintenance activities.
3.5 (continued) EHS4 - Written, up-to- Are there established programs to protect site groundwater?
date health and safety... Guidance:
procedures appropriate to
the facility…EHS13 - Look for specific reference to EHS issues in operating and
…maintenance maintenance procedures, including:
…programs to maintain •PPE requirements,
the safety of facilities, •special training requirements,
tools and •potential process/chemical hazards,
equipment…EHS15 - •lockout/tagout, confined space entry, hotwork,
Security procedures and linebreaking, and other “permit” activities,
systems to control entry •emergency procedures,
and exit of personnel and •operating limits to avoid emissions or wastewater
materials... beyond established parameters; and
PP13 - Implementation •consequences of deviation.
of...operating controls Ask for an actual SOP or maintenance procedure to show
…to improve prevention PPE, Training, MSDSs, etc.
of and early detection of
releases... Look for programs in place and systems to track reductions.
D4.1 - Documented These will probably have been mentioned in the goal setting
procedures for the answers.
selection and use of
containers...D4.2 - Do not look for the details of pollution prevention projects
Documented procedures and the efficiency of the wastewater treatment plant or
for loading remediation activities. Past problems and monitoring, while it
chemicals...D4.3 - is a groundwater protection measure, is usually a regulatory
Documented procedures requirement. Look for measures to protect from current
for unloading potential sources.
chemicals...D4.4 -
Defined criteria for the Look for engineering standards for new construction that
cleaning and return... relate to spill and groundwater protection.
20

standards
3.6 documented site emergency ER2 - A current, written Potential Questions: ISO 4.4.7
response plans with appropriate facility emergency
considerations of communications and response plan which Have proper procedures been established to identify the UK-CIA 5.5,
community recovery needs, participation in addresses, among other potential for and to respond to accidents and emergency 7.5.5
development of community emergency things, communications situations and for preventing and mitigating the associated
preparedness planning, and a documented and the recovery needs EHS impacts?
process for responding to chemical of the community.
transportation incidents. ER4 - Emergency Are such procedures periodically tested as reviewed/revised
exercises...to test after tests or after actual incidents?
operability of the...plan.
Guid Princ9 - To lead in Are local emergency response professionals trained about
the development of the hazards of the facility?
responsible laws,
regulations...standards Are local emergency responders familiar with the plant and
that safeguard the with the hazards?
community, workplace
and environment. Does the emergency response plan address community
CA7 - An outreach recovery needs in the aftermath of an event that could has
program to educate off-site impact?
responders, government
officials, the media, other Has the organization adequately addressed off-site
businesses and the emergencies involving its products or raw materials?
community
about...emergency Has the organization worked to integrate its emergency
response... response plan into the community emergency response
ER5 – Communication of plan?
relevant and useful
emergency response
planning information to
the LEPC.
21

standards
3.6 (continued) ER6 - Facility tours for Guidance:
emergency response
personnel to promote Emergency Response Plan and Community Recovery
emergency
preparedness... Look at the emergency response plan, starting with the table
ER7 – Coordination of the of contents to determine what areas it covers
written facility emergency
response plan with the Community recovery needs relates to having documented
comprehensive plans or a policy to take car of things like housing, medical
community response expenses, etc. in the aftermath of a catastrophic release or
plan... If no plan exists incident that results in evacuation, property damage, or
the facility should initiate personal injury
community efforts... Community Preparedness Planning
ER8 – Participation in the
community emergency Community preparedness planning is typically handled
response planning through LEPC involvement
process...
ER9 - Sharing of If the company is not active with the LEPC, look for
information and expertise participation in community emergency response drills, fire
relating to emergency department tours, etc.
response planning,
exercises, and the Transportation Emergency Response
handling of incidents with
other facilities... Regarding transportation emergency response look for:
D5.2 – Documented • Provision of technical assistance to on-scene
procedures for making responders, with internal notification systems
information...available to concerning off-site events, typically through
response agencies. CHEMTREC
• Use of contract emergency responders to physically
respond to off-site emergencies involving the
organization’s products
22

standards
• Hands-on response by company response personnel
D5.3 - A program for and company equipment to off-site emergencies
3.6 (continued) making facilities and/or • A combination of the above
training materials
available to emergency Evaluate how the organization’s transportation emergency
response agencies. response system is implemented commensurate with
D5.1 - A process for product risk
responding to chemical
distribution Judgment as to what is adequate must relate to the nature of
accidents/incidents the product hazard and the level of product transportation
involving the company’s exposure
chemicals.
This system relies on an adequate assessment of
transportation risk as addressed in element 2.1
Look for participation in mutual assistance networks, such as

CHEMNET or CIMA
3.7 a system to provide appropriate Guid Princ5 – To work Potential Questions: ISO 4.4.6
guidance, information and training with customers... to foster
requirements to carriers, distributors, safe use, transport and Has the organization developed adequate systems for the UK-CIA 5.3,
customers, contractors, and third party disposal of chemicals. communication of product and process risk-related guidance, 6.4, 6.6.3,
providers on the risks and hazards of the Guid Princ10 – To information and training requirements to its: 7.3.1, 7.5.4
organization’s products and processes, and practice Responsible • carriers?
for receiving guidance and information from Care by encouraging … • distributors?
suppliers on goods and services used by others to adhere to these • customers?
the organization. principles and practices. • contractors?
• other third party providers as defined by the
organization?
Has the organization developed adequate systems to receive
risk-related guidance, information and training requirements
23

standards
from its suppliers?
D2.3 - A program for
3.7 (continued) providing guidance and
information to carriers, Guidance:
distributors and This question is about sharing risk information with an
contractors...on...training organization’s commercial partners. It usually is answered
and compliance with the fact that MSDSs are provided or there is training
requirements... offered, etc.
D4.5 - A program for
providing guidance and This same question should be asked by the auditor for each
information to customers, commercial partner, along with the following about qualifying
distributors, and other and the one about tracking performance of these partners
receivers... (elements 3.8, 3.9, 4.2).
PS9 - Provides Look for a detailed system to share risk information with all
information and commercial partners that includes on-site training, process
guidance...to (Contract design input, etc.
Manufacturers)...
PS10 - Requires This is also about receiving risk information from suppliers --
suppliers to provide usually it is answered with the fact that MSDSs are provided
appropriate...information or there is training offered, etc.
and guidance...
PS11 -
Provides...information to
distributors...
PS12 -
Provides...information to
direct product receivers...
24

standards
3.8 a system that includes PSM22 -Provisions that Potential Questions: UK-CIA
environmental, health and safety contractors...have 7.2.1, 7.2.4,
performance for the qualification and programs for their own Has the organization developed systems that include EHS 7.5.4
selection of suppliers, carriers, distributors employees consistent performance considerations in the qualification and selection
contractors and third-party providers. with…the Code... of its:
EHS3 - Provisions, •suppliers?
including selection •carriers?
criteria, to confirm •distributors?
contractors’ programs are •contractors?
consistent with...this •other third party providers as defined by the organization?
Code. Guidance:
PP12 - Implementation of This question relates to the qualification of commercial
a process for selecting, partners based on their EHS performance. Look for criteria
retaining...contractors that are understood throughout the organization. These can
and toll manufacturers include safety records, recordable and lost time injury rates,
taking into etc.
account...practices that
protect the environment In some cases, the selection process might be a
and the health and safety corporate/division/business unit function. Look for the plant’s
of employees and the knowledge about the company’s selection process.
public.
D3.1 - A process for While some of the qualification criteria relates to price and
qualifying carriers...that quality, look for EH&S qualification systems.
emphasizes carrier safety
fitness and regulatory Look for the use of the ACC’s Commercial Partner Selection
compliance… Protocols. While not required, these may be used to address
D4.6 - A process for this element.
selecting distributors...
that emphasizes safety
fitness and regulatory
compliance...
25

standards
3.8 (continued) PS9 - Selects contract

manufacturers who
employ appropriate
practices for health,
safety, and environmental
protection...
PS11 -... Factors
adherence to sound
health, safety and
environmental
principles... into
procurement decisions.
3.9 a system to determine that PS12 - Commensurate Potential Questions: UK-CIA 7.5.4
customers can safely handle company with product risk, works
products. with {customers} to foster Has the organization developed systems to determine that
proper use, handling, customers can safely handle its products?
recycling, disposal…
Work with the product Guidance:
receiver to improve
{improper} practices. If, This element relates to the qualification of customers, or
in the company’s more specifically the determination that those who buy and
independent judgment, use the company’s products have the ability to do so safely.
improvement is not Look for criteria that are understood throughout the
evident, then the organization. These can include safety and environmental
company should take records, recordable and lost time injury rates, etc.
further measures – up to
and including termination Look for the use of the ACC’s Commercial Partner Selection
of product sale. Protocols. While not required, these may be used to address
this element.
26

standards
3.10 procedures for establishing, PSM7 - Current, Potential Questions: ISO 4.4.4
maintaining and controlling documents and complete documentation UK-CIA 6.5.3
information required by the Responsible of process design, Have proper document control procedures been established
Care Management System to ensure that operating parameters and and maintained to ensure that:
they can be: a) located; b) periodically procedures. • Documents can be located?
reviewed, revised and approved by PSM8 - Current, • They are periodically reviewed, revised as necessary,
authorized personnel; c) are available at all complete documentation and approved by authorized personnel?
applicable locations where essential; d) are of information relating to • The current versions are available at all locations?
legible, dated with changes readily the hazards of materials • Obsolete documents are removed from the system or
identifiable and properly retained; e) and process technology. otherwise assured against unintended use?
describe the core elements of the EHS6 - Systems for • Obsolete documents retained for legal and / or
management system and their interaction; maintaining records and knowledge preservation purposes are suitably
and f) provide direction to related analyzing data to identified?
documentation. Procedures and evaluate health and
responsibilities shall be established and safety performance, Is documentation legible, dated (with dates of revision) and
maintained concerning the creation and determine trends and readily identifiable, maintained in an orderly manner and
modification of the various types of identify areas for retained for a specified time period?
documents, and the periodic review and improvement.
removal of obsolete documents. Have procedures and responsibilities been established and
Documents and information can be in maintained concerning the creation and modification of the
paper or electronic form. various types of documents?
Guidance:
This element is ISO-specific and not found directly in

Responsible Care. It requires the auditor to obtain
documented evidence that all the systems reviewed
throughout the audit are documented and easily produced.
27

standards
3.10 (continued)
The company must demonstrate that these documents are
periodically reviewed, revised, and approved through a
document control system that covers all aspects of the
Responsible Care management system.
The auditor should assess the availability of documents at

applicable locations where essential. (e.g. Are operating and
emergency response procedures available in control rooms?
Are operators aware of these documents?)
The auditor should assess that documents are legible and

current, and that changes are easily identified.
Finally, the auditor should assess the company’s system of

accountability to create, maintain, modify, and remove
obsolete documents. (e.g., are there individuals designated
by job descriptions responsible for this?)
28

standards
4.1 The organization shall PSM3 - Measurements of Potential Questions: ISO 4.5.1
demonstrate the use of performance performance...
measurement and corrective and PSM4 -...reporting...of Have documented procedures been established and UK-CIA 5.4
preventive action by: each incident that results maintained for monitoring and measuring on a regular basis
or could have resulted in the key characteristics of the operations and activities that
establishing and maintaining documented a fire, explosion or can have a significant environmental, health and safety
procedures to monitor and measure on a accidental chemical impact including, recording of information to track
regular basis the key characteristics release. performance, relevant operational controls and conformance
relevant to its products and activities on EHS10 - Employee with the organization’s environmental, health and safety
environment, health and safety. occupational surveillance objectives and targets?
programs...
PP2 - A quantitative Guidance:
inventory at each facility
of wastes generated and This element is ISO-specific and not found directly in
releases to the air, water Responsible Care. It refers to monitoring and measuring key
and land... characteristics of an organization’s product and activities.
PP7 - Measurement of
progress at each facility This must be broadened to handle all Responsible Care
in reducing...wastes and elements.
in reducing the
releases...by updating the
quantitative inventory at
least annually.
D1.3 - Internal
reporting...of chemical
distribution
accidents/incidents...
29

standards
4.2 reviewing the environmental, PP12 - Implementation of Potential Questions: UK-CIA 5.4,
health and safety performance of carriers, a process for...reviewing 7.2.1, 7.2.2
suppliers, distributors, customers, contractors and toll Has the organization developed systems to track and review
contractors and third party providers for manufacturers... EHS performance of its:
use in qualification reviews. D3.1 - A process • suppliers?
for...carriers...and • carriers?
includes regular reviews • distributors?
of their performance... • contractors?
D3.2 - Feedback to
• customers?
carriers on their safety
• other third party providers as defined by the
performance...
organization?
PS9 - ...periodically
Guidance:
reviews performance of
This is part of the trio of questions asked about commercial
contract manufacturers.
partners. After the organization has qualified a company
PS11 - ...periodically
(3.8, 3.9) and provided them with risk information (3.7), look
reviews distributors to
for information about their ongoing performance.
foster proper use,
handling, recycling,
Ask how the tracking of that performance feeds back to the
disposal and...
re-qualification process.
PS12 - …work with the
product receiver to
improve {improper}
practices. If, in the
company’s independent
judgment, improvement is
not evident, then the
company should take
further measures – up to
and including termination
of product sale.
30

standards
4.3 accident and incident PSM3 - ...implementation Potential Questions: ISO 4.5.2
investigations that identify the causes of of corrective action
the occurrence and lead to the PSM4 - Have procedures been established and maintained for UK-CIA 6.1,
recommendation and implementation of Investigation...and defining responsibility and authority for handling and 8.4
corrective and preventive action. appropriate corrective investigating nonconformance, taking action to mitigate any
action and follow-up of impacts caused and initiating and completing corrective and
each incident that results preventative action?
or could have resulted in
a fire, explosion or Have all corrective or preventative action taken to eliminate
accidental chemical the causes of actual and potential non conformances been
release. appropriate to the magnitude of problems and
EHS14 - Timely commensurate with the environmental, health and safety
investigation of work site impact encountered?
illnesses, injuries and
accidents; corrective Has the organization implemented and recorded any
actions to prevent changes in the documented procedures resulting from
recurrence... corrective and preventive action?
D1.3 -
Internal...investigation of Guidance:
chemical distribution
accidents/incidents, and Look for a comprehensive description of procedures for
implementation of environmental, health, and safety incident investigation that
preventive measures. should be understood throughout the organization. Include
near hits or near misses.
Ask for the incident and accident investigation form, if there

is one.
31

standards
4.4 the maintenance of sufficient EHS6 - Systems for Potential Questions: ISO 4.5.3
records to enable analysis of Responsible maintaining records and
Care trends and performance. analyzing data to Are the records legible, identifiable and traceable to the UK-CIA 8.0,
evaluate health and activity, product or service involved? Are the records stored 8.5
safety performance, and maintained in such a way that they are readily
determine trends and retrievable and protected against damage, deterioration or
identify areas for loss and are their retention times established and recorded?
improvement.
Are records maintained, as appropriate to the system and to
the organization, to demonstrate conformance to the
requirements of this Standard?
Guidance:
This element is usually coupled with describing the accident

and incident investigation process (4.3) and the tracking of
key characteristics (4.1). Look for paper or electronic
systems to keep track of incidents and tabulate them.
4.5 periodic evaluation of compliance PSM3 - ...audits for Potential Questions: ISO 4.5.1
with relevant regulations. compliance...
D2.4 - Regular reviews Are there established and maintained documented UK-CIA 8.3
of... compliance with procedures for the periodic evaluation of compliance with
applicable regulations relevant environmental, health and safety legislation and
and company regulations?
requirements.
Guidance:
This element focuses on the organization’s regulatory

compliance auditing system.
32

standards
4.5 (continued) Potential areas of interest include:

Is this done from a central corporate group? Auditors from
other plants? What frequency? Combine environmental,
health, and safety? What about the findings? Who sees
them? What about corrective actions based on the audit?
How are they tracked? Who is accountable? Are these
systems audits or simply audits versus compliance?
Often, plants will talk about inspections and safety tours. An

audit is measuring something versus a standard or a
regulation – not an inspection to look at safety conditions.
Look for a true audit that measures against regulations
and/or company or industry standards.
4.6 periodic audits of the EHS5 - Means to verify Potential Questions: ISO 4.5.4
Responsible Care Management System by that health and safety
the organization. programs and procedures Does the organization have a program and procedures for UK-CIA 6.1,
are effective and that periodic Responsible Care management system audits in 7.4.5, 8.1, 8.3
actual practices are order to determine if the Responsible Care management
consistent with these system
programs and
procedures. • Conforms to planned arrangements for Responsible
PP11 - Periodic Care management including the requirements of this
evaluation of waste Standard?
management practices... • Has been properly implemented and maintained?
• Provides information on the results of audits to
management?
Is the organization’s audit program, including any schedule,

based on the environmental, health and safety importance of
33

standards
the activity concerned and the results of previous audits?
4.6 (continued)
In order to be comprehensive, do the audit procedures cover
the audit scope, frequency and methodologies, as well as the
responsibilities and requirements for conducting audits and
reporting results?
Guidance:
This is not a regulatory compliance audit. This is an audit of

the Responsible Care Management System (i.e. this
Standard, practice in place reviews, etc.).
4.7 the regular evaluation of the CA5 – … evaluation of Potential Questions:
effectiveness of its communications the effectiveness of the
programs with its stakeholders; ongoing employee Does the organization have formal procedures addressing
communications the periodic evaluation of communications effectiveness with
efforts…CA10 - A regular its stakeholders, including:
evaluation of the • community?
effectiveness of the • employees?
ongoing community • other stakeholders as defined by the organization?
communications efforts.
Guidance:
Surveys and CAPs can do both – but this is more of an after-

the-fact question as opposed to processes in place in to be
aware of concerns as they are emerging.
Could include surveys and focus groups.
34

standards
4.8 defining responsibility and EHS14 - Timely Potential Questions: ISO 4.5.2
authority for handling and investigating investigation of work site
nonconformance, taking action to mitigate illnesses, injuries, and Has the organization established and maintained a system to UK-CIA 6.5.3
any impacts caused and for initiating and incidents; corrective follow up on any nonconformances, including taking action to
completing corrective and preventive actions to prevent mitigate any impacts caused?
action. recurrence; and
evaluation of the Are there clearly defined responsibilities and authorities
effectiveness of established for handling and investigating any
corrective actions taken. nonconformances?
PSM3 - Measurement of
performance, audits for Is there a system to initiate and complete corrective and
compliance and preventive actions as a result of identified
implementation of nonconformances?
corrective actions.
Guidance:
This is simply looking for evidence of a system to follow up

on any non-conformance (e.g., audit findings, incident
investigation results, etc.) with corrective and preventive
action.
There should be documented accountabilities and timetables

for completion of non-conformance-related actions.
4.9 the identification, maintenance Potential Questions: UK-CIA 6.5.2
and disposition of Responsible Care
Management System records. These Are there clearly documented records related to equipment
records shall include equipment calibration, monitoring and calibration?
training records and the results of audits Has the organization established and maintained a system to
and reviews. These records shall be track employee training needs and records of completion?
legible, identifiable, traceable to the activity,
product or service involved, properly stored Does the organization maintain a document system related
35

standards
and maintained. to audit results and associated corrective actions?
4.9 (continued)
Has the organization established and maintained procedures
for the identification, maintenance and disposition of
environmental, health and safety records, including training
records and results of audits and reviews?
Are records legible, identifiable, traceable to the activity,
product or service involved?
Are records properly stored and maintained?
Guidance:
Look for an appropriate repository for Responsible Care
management system records.
Records include equipment calibration, training information,
audit results, policy reviews, performance reviews, etc.
Look for how the company keeps track of training – training
matrices, how they know who needs to be trained, what
training is needed, and who has been trained. How is it
documented?
36

standards
4.10 calibration and maintenance of Potential Questions: ISO 4.5.1
monitoring equipment.
Is monitoring equipment calibrated and maintained and are UK-CIA 5.4
records of this process retained according to the
organization’s procedures?
Guidance:
Here, the auditor should assess the company’s system to

calibrate and maintain monitoring equipment.
This relates to process and environmental, health, and safety

standards. Equipment may include stack testing, water
sampling, industrial hygiene monitoring, etc.
37

standards
5.1 Management Review and EHS14 - Timely Potential Questions: ISO 4.6
Reporting shall be demonstrated by investigation of work site ISO 4.4.1
evidence of: illnesses, injuries, and Does the organization’s top management, at intervals that it
incidents; corrective determines, review the environmental, health and safety UK-CIA 9.0,
periodic reviews of the organization’s actions to prevent management system, to ensure its continuing suitability, 9.1, 9.2, 9.3
Responsible Care Management System, to recurrence; and adequacy and effectiveness? Does the management review
ensure its continuing suitability, adequacy evaluation of the process ensure that all the necessary information is collected
and effectiveness. The management effectiveness of to allow management to carry out this evaluation? Is this
review process shall ensure that the corrective actions taken. review documented?
necessary information is collected to allow PSM3 - Measurement of
management to carry out this evaluation. performance, audits for Does the management review address the possible need for
This review shall be documented and compliance and changes to policy, objectives and other elements of the
address the possible need for changes to implementation of environmental, health and safety management system, in
policy, goals, objectives and other corrective actions. light of the environmental, health and safety management
elements of the Responsible Care system audit results, changing circumstances and the
Management System, changing commitment to continual improvement?
circumstances and the commitment to
continual improvement. Guidance:
This element is self-explanatory. It relates to management

involvement in the review of policy and objectives.
5.2 reporting mechanisms to Guid Prin4 - To provide Potential Questions: ISO 4.4.3
stakeholders, including top management, information on health or
employees and the public about the environmental risks and Does the organization have systems to report information UK-CIA 9.3
environmental, health, and safety pursue protective about the organization’s Responsible Care Management
performance. measures for employees, System performance to its stakeholders, including:
the public and other key • top management?
stakeholders. • employees?
• the public?
• other stakeholders as defined by the organization?
38

standards
5.2 (continued) PP8 - Ongoing dialogue

with employees and Guidance:
members of the public
regarding waste and Here, auditors should look for systems to share Responsible
release information, Care management system performance information with the
progress in achieving organization’s stakeholders. These include internal and
reductions, and future external stakeholders.
plans...
Auditors should verify that this information includes
environmental, health, and safety / Responsible Care
performance metrics (e.g., emissions data, injury rates,
Responsible Care Code performance metrics, etc.)
5.3 participation in mutual assistance Guid Princ 10 – To Potential Questions:
programs and sharing activities as practice Responsible
embodied in the Responsible Care Guiding Care by encouraging and Does the organization demonstrate the review of its
Principles and Codes of Management assisting others to adhere Responsible Care Management System and programs with
Practices. to these principles and other companies and peers through participation in mutual
practices assistance programs and sharing activities?
ER9 - Sharing of Guidance:
information and expertise This is to determine that a company looks to others for
relating to emergency benchmarking.
response planning,
exercises and the Some examples that provide benchmarking opportunities
handling of incidents with are: trade associations – local and national, chemical
other facilities... industry councils, consultants, employee committees visiting
PSM5 - Sharing of other companies, customers and suppliers and other
relevant safety commercial partners, ACC Responsible Care – Executive
knowledge and lessons Leadership Groups.
learned from...with
industry...
39

standards
5.4 a performance management PSM2 - Clear Potential Questions:
system for employees that recognizes accountability for
environmental, health, safety, and performance against Have procedures been established and maintained to make
Responsible Care excellence. specific goals ..... employees or members of each relevant function and level
aware of the significant EHS impacts of their work activities
and the EHS benefits of improved personal performance?
Is there an employee performance management system that

recognizes EHS and Responsible Care excellence at all
levels of the organization?
Guidance:
Employee performance management includes performance

reviews or evaluations. Look for indications that the
company’s performance review process includes
environmental, health, and safety or Responsible Care as
part of the review for the appropriate employees.
Look for indications that the organization’s performance

review process includes EHS or Responsible Care as part of
the review for employees
This may or may not extend to hourly employees. If it

doesn’t, evaluate how the organization stresses the
importance of EHS and Responsible Care excellence to the
hourly work force.
40

Attachment 1
Responsible Care®
Guiding Principles
Responsible Care® Guiding Principles
Our industry creates products and services that make life better for people around the
world — both today and tomorrow. The benefits of our industry are accompanied by
enduring commitments to Responsible Care® in the management of chemicals
worldwide. We will make continuous progress toward the vision of no accidents, injuries
or harm to the environment and will publicly report our global health, safety and
environmental performance. We will lead our companies in ethical ways that
increasingly benefit society, the economy and the environment while adhering to the
following principles:
· To seek and incorporate public input regarding our products and operations.
· To provide chemicals that can be manufactured, transported, used and disposed of
safely.
· To make health, safety, the environment and resource conservation critical
considerations for all new and existing products and processes.
· To provide information on health or environmental risks and pursue protective
measures for employees, the public and other key stakeholders.
· To work with customers, carriers, suppliers, distributors and contractors to foster the
safe use, transport and disposal of chemicals.
· To operate our facilities in a manner that protects the environment and the health and
safety of our employees and the public.
· To support education and research on the health, safety and environmental effects of
our products and processes.
· To work with others to resolve problems associated with past handling and disposal
practices.
· To lead in the development of responsible laws, regulations and standards that
safeguard the community, workplace and environment.
· To practice Responsible Care® by encouraging and assisting others to adhere to these
principles and practices.
Attachment 2
Responsible Care®
Codes of Management Practices
Community Awareness and Emergency

Response
Pollution Prevention
Process Safety
Distribution
Employee Health and Safety
Product Stewardship
COMMUNITY AWARENESS AND EMERGENCY RESPONSE
CODE OF MANAGEMENT PRACTICES
Purpose
The goal of the Community Awareness and Emergency Response (CAER) Code of Management Practices
is to assure emergency preparedness and to foster community right-to-know. It demands a commitment
to openness and community dialogue. The code has two major components: first, to assure that member
facilities that manufacture, process, use, distribute or store hazardous materials initiate and maintain a
community outreach program to openly communicate relevant, useful information responsive to the
public's questions and concerns about safety, health, and the environment; and second, to help protect
employees and communities by assuring that each facility has an emergency response program to
respond rapidly and effectively to emergencies.
The community outreach component will communicate program activities and performance under all
codes of management practices and will promote an open, ongoing dialogue with employees and the
community. Information should be provided about such activities as waste minimization, emission
reduction, health effects of chemicals, and efforts to ensure the safe transport of chemicals.
The CAER Code of Management Practices is supported by, and will build on, the Council’s CAER
process. CAER supports the community's right to know about chemical industry operations and their
effect on safety, health, and the environment. CAER originally was a voluntary initiative focused on
emergency response issues. The new CAER Code of Management Practices broadens the facility-
community dialogue to cover the full range of safety, health and environmental issues.
Relationship to Guiding Principles
The Code helps achieve several of the Responsible Care® Guiding Principles:
• To seek and incorporate public input regarding our products and operations.
• To provide information on health or environmental risks and pursue protective measures for
employees, the public and other key stakeholders.
• To lead in the development of responsible laws, regulations and standards that safeguard the
community, workplace and environment.
®
• To practice Responsible Care by encouraging and assisting others to adhere to these principles and
practices.
Management Practices
A. Community Awareness and Outreach
Member facilities that manufacture, process, use, distribute or store hazardous materials shall have
a community outreach program that includes:
For Employees:
1. An ongoing assessment of employee questions and concerns about the facility.
2. Communications training for key facility and company personnel who communicate with
employees and the public concerning safety, health, and environmental issues.
3. Education of employees about the facility's emergency response plan and safety, health, and
environmental programs.
4. An ongoing dialogue with employees to respond to their questions and concerns and involve
them in community outreach efforts.
5. A regular evaluation of the effectiveness of the ongoing employee communications efforts.
For Community:
6. An ongoing assessment of community questions and concerns about the facility.
7. An outreach 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.
8. A continuing dialogue with local citizens to respond to questions and concerns about safety,
health, and the environment, and to address other issues of interest to the community.
9. A policy of openness that provides convenient ways for interested persons to become familiar
with the facility, its operations, and products, and its efforts to protect safety, health, and the
environment.
10. A regular evaluation of the effectiveness of the ongoing community communications efforts.
B. Emergency Response and Preparedness
Member facilities that manufacture, process, use, distribute or store hazardous materials shall have
an emergency response program that includes:
1. An ongoing assessment of potential risks to employees and local communities resulting from
accidents or other emergencies.
2. A current, written facility emergency response plan which address, among other things,
communications and the recovery needs of the community after an emergency.
3. An ongoing training program for those employees who have response or communications
responsibilities in the event of an emergency.
4. Emergency exercises, at least annually, to test operability of the written emergency response
plan.
5. Communication of relevant and useful emergency response planning information to the Local
Emergency Planning Committee.
6. Facility tours for emergency responders to promote 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.
POLLUTION PREVENTION
Purpose
This Code is designed to achieve ongoing reductions in the amount of all contaminants
and pollutants released to the air, water, and land from member company facilities.
These reductions are intended to respond to public concerns with the existence of such
releases, and to further increase the margin of safety for public health and the
environment.
The Code is also designed to achieve ongoing reductions in the amount of wastes
generated at facilities. These reductions are intended to help relieve the burden on
industry and society of managing such wastes in future years.
In implementing the Code, each company should strive for annual reductions,
recognizing that production rates, new operations, and other factors may result in
increases. Despite these fluctuations, however, the goal is to establish a long-term,
substantial downward trend in the amount of wastes generated and contaminants and
pollutants released. Quantitative reduction goals will be established for giving priority
to those pollutants, contaminants and wastes of highest health and environmental
concern.
This code also includes practices that address the broader waste management issues
beyond source reduction and other waste and release reduction efforts. Each member
company must manage remaining wastes and releases in a manner that protects the
environment and the health and safety of employees and the public.
This Code complements, and should be implemented in conjunction with current and
future Codes of Management Practices. Key terms are defined in the Glossary, which
should be consulted for assistance in interpreting the provisions of this Code.
Implementation of this Code helps achieve the following Guiding Principles:
• To provide chemicals that can be manufactured, tansported, used and disposed of
safely .
• To make health, safety, the environment and resource conservation critical

considerations for all new and existing products and proocesses.
• To provide information on health or environment risks and pursue protective

measures for employees, the public and other key stakeholders.
• To operate our facilities in a manner that protects the environment and the health
and safety of our employees and the public.
• To support education and research on the health, safety and environmnental effects
of our products and processes.
• To work with others to resolve problems associated with past handling and disposal
practices.
• To lead in the development of responsible laws, regulations and standards that

safeguard the community, workplace and environment.
• To practice Responsible Care® by encouraging and assisting others to adhere to

these principles and practices.
Each member company shall have a pollution prevention program which shall include:
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.
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.
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.
4. Education of, and dialogue with, employees and members of the public about the
inventory, impact evaluation, and risks to the community.
5. Establishment of priorities, goals and plans for waste and release reduction,
taking into account both community concerns and the potential health, safety,
and environmental impacts as determined under Practices 3 and 4.
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 in 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 of the public regarding waste
and release information, progress in achieving reductions, and future plans. This
dialogue should be at a personal, face-to-face level, where possible, and should
emphasize listening to others and discussing their concerns and ideas.
9. Inclusion of waste and release prevention objectives in research and in design of

new or modified facilities, processes, and products.
10. An ongoing program for promotion and support of waste and release reduction
by others, which may, for example, include:
a. Sharing of technical information and experience with customers and

suppliers;
b. Support of efforts to develop improved waste and release reduction

techniques;
c. Assisting in establishment of regional air monitoring networks;
d. Participation in efforts to develop consensus approaches to the evaluation

of environmental, health, and safety impacts of releases;
e. Providing educational workshops and training materials;
f. 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.
12. Implementation of a process for selecting, retaining, and reviewing contractors

and toll manufacturers taking into account sound waste management practices
that protect the environment and the health and safety of employees and the
public.
13. Implementation of engineering and operating controls at each member company

facility to improve prevention of and early detection of releases that may
contaminate groundwater.
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.
PROCESS SAFETY
Purpose
The Process Safety Code is designed to prevent fires, explosions and accidental chemical releases. The
Code is comprised of a series of management practices that reflect this goal, with the expectation of
continuous performance improvement for each management practice. The practices are based on the
principle that facilities will be safe if they are designed according to sound engineering practices, built,
operated and maintained properly and periodically reviewed for conformance.
Process safety is an interdisciplinary effort. Consequently, the Code is divided into the following four
elements: management leadership, technology, facilities and personnel. Each element is composed of
Management Practices. Individually, each Practice describes an activity or approach important to
preventing fires, explosions and accidental chemical releases. Collectively, the Practices encompass
process safety from the design stage through operation, maintenance and training. The scope of this
Code includes manufacturing, processing, handling and on-site storage of chemicals. This Code must be
implemented with full recognition of the community’s interest, expectations and participation in
achieving safe operations.
The process safety management program in each facility is complemented by workplace health and
safety programs, as well as waste and release reduction programs which address and minimize releases
and waste generation. These three programs, and others, will help assure that member facilities are
operated in a manner that protects the environment and the health and safety of personnel and the
public.
The Code helps achieve several of the Responsible Care® Guiding Principles:
• To make health, safety, the environment and resource conservation critical considerations for all
new and existing products and processes .
• To operate our facilities in a manner that protects the environment and the health and safety of our
employees and the public.
Each member company shall have an ongoing process safety program that includes:
Management Leadership
1. Leadership by senior management through policy, participation, communications and resource

commitments in achieving continuous improvement of performance.
2. Clear accountability for performance against specific goals for continuous improvement.
3. Measurement of performance, audits for compliance and implementation of corrective actions.
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.
5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry,
government and the community.
6. Use of the Community Awareness and Emergency Response (CAER) process to assure public
comments and concerns are considered in design and implementation of the facility’s process safety
systems.
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.
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.
10. Management of changes to chemical operations to maintain or enhance the safety originally
designed into the facility.
Facilities
11. Consideration and mitigation of the potential safety effects of expansions, modifications and new
sites on the community, environment, and employees.
12. Facility design, construction and maintenance using sound engineering practices consistent with
recognized codes and standards.
13. Safety reviews on all new and modified facilities during design and prior to start-up.
14. Documented maintenance and inspection programs that ensure facility integrity.
15. Sufficient layers of protection through technology, facilities and employees to prevent escalation
from a single failure to a catastrophic event.
16. Provision for control of processes and equipment during emergencies resulting from natural events,
utility disruptions and other external conditions.
Personnel
17. Identification of the skills and knowledge necessary to perform each job.
18. Establishment of procedures and work practices for safe operating and maintenance activities.
19. Training for all employees to reach and maintain proficiency in safe work practices and the skills
and knowledge necessary to perform their job.
20. Demonstrations and documentation of skill proficiency prior to assignment to independent work,
and periodically thereafter.
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.
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.
Distribution
Code of Management Practices
Purpose
The purpose of the Distribution Code of Management Practices is to reduce the risk of harm posed by the
distribution of chemicals to the general public; to carrier, distributor, contractor and chemical industry
employees; and to the environment. Adherence to the code will lead to continually safer chemical
distribution and help member companies to:
• evaluate the risks associated with chemical distribution and methods to reduce those risks;
• meet or exceed all regulations and industry standards governing chemical distribution;
• provide emergency advice and/or assistance to people on the scene in the event of a chemical
distribution emergency;
• develop new technologies and methods to improve chemical distribution safety.
The code will also promote improvements in:
• employee preparedness and awareness in preventing distribution emergencies;
• the safety performance of carriers and other providers of distribution services;
• the public’s preparedness in responding to chemical distribution emergencies;
• the public’s understanding of, and confidence in, industry efforts to improve chemical distribution
safety.
The Distribution Code of Management Practices applies to all modes of transportation (highway, rail,
marine, air and pipeline) and to the shipment of all chemicals, including chemical waste. The code also
applies to distribution activities (storage, handling, transfer and repackaging) while chemicals are in
transit between member companies and their suppliers and customers. The implementation of a number
of practices of the code will vary according to the characteristics of the chemical being distributed, the
mode of transportation and the type of distribution activity involved.

This code helps achieve several Responsible Care® Guiding Principles:
• To seek and incorporate public input regarding our products and operations;
• To make health, safety, the environment and resource conservation critical considerations for all
new and existing products and processes;
• To work with customers, carriers, suppliers, distributors and contractors to foster the safe use,
transport and disposal of chemicals;
• To operate our facilities in a manner that protects the environment and the health and safety of our
employees and the public;
• To lead in the development of responsible laws, regulations and standards that safeguard the
community, workplace and environment;
• To practice Responsible Care® by encouraging and assisting others to adhere to these principles and
practices.
Each member company shall have an ongoing chemical distribution safety program that includes senior
management commitment through policy, communications and resources to improvements in chemical
distribution safety. The program should include the following elements:
1. Risk Management
1.1 Regular evaluations of chemical distribution risks which consider the hazards of the material,
the likelihood of accidents/incidents and the potential for human and environmental exposure
from release of the material over the route of transport.
1.2 Implementation of chemical distribution risk reduction measures that are appropriate to the
risk level.
1.3 Internal reporting and investigation of chemical distribution accidents/incidents, and

implementation of preventive measures.
2. Compliance Review and Training
2.1 A process for monitoring changes and interpretations of new and existing regulations and
industry standards for their applicability to the company’s chemical distribution activities, and
for implementing those regulations and standards.
2.2 Training for all affected company employees in the proper implementation of applicable
regulations and company requirements.
2.3 A program for providing guidance and information to carriers, distributors and contractors
who perform distribution activities for the company on the company’s training and
compliance requirements for the activities.
2.4 Regular reviews of company employee, carrier, distributor and contractor compliance with
applicable regulations and company requirements.
3. Carrier Safety
3.1 A process for qualifying carriers of all modes and types (common, contract, private and
customer controlled) that transport chemicals to and from company facilities that emphasizes
carrier safety fitness and regulatory compliance, and includes regular reviews of their
performance and compliance.
3.2 Feedback to carriers on their safety performance and suggestions for improvement.
4. Handling and Storage
4.1 Documented procedures for the selection and use of containers that are appropriate for the
chemical being shipped, in compliance with testing and certification requirements, and free of
leaks and visible defects.
4.2 Documented procedures for loading chemicals at company facilities that will reduce emissions
to the environment, protect personnel and provide securement of the lading during transit.
4.3 Documented procedures for unloading chemicals at the company’s facilities that will reduce
emissions to the environment, protect personnel, and provide for safe unloading into proper
storage facilities.
4.4 Defined criteria for the cleaning and return of tank cars, tank trucks, marine vessels, and
returnable/refillable bulk and semi-bulk containers, and for the proper disposal of cleaning
residues.
4.5 A program for providing guidance and information to customers, distributors, and other
receivers on proper procedures for unloading and storing the company’s chemicals.
4.6 A process for selecting distributors and other facilities that store or handle the
company’s chemicals in transit that emphasizes safety fitness and regulatory compliance and
includes regular reviews of their performance and compliance.
4.7 Feedback to distributors and operators of other facilities that store or handle chemicals in
transit on their safety performance and suggestions for improvement.
5. Emergency Preparedness
5.1 A process for responding to chemical distribution accident/incidents involving the company’s
chemicals.
5.2 Documented procedures for making information about the company’s chemicals in
distribution available to response agencies.
5.3 A program for making facilities and/or training materials available to emergency response
agencies.
5.4 Dialogue with state and local emergency planning organizations on the distribution and
hazards of the company’s chemicals to improve community preparedness to respond to
chemical distribution emergencies.
5.5 Dialogue with the public on their concerns about chemical distribution safety, actions taken by
the industry and the company to improve the safety of chemical distribution, and the
effectiveness of emergency preparedness and emergency response assistance.
EMPLOYEE HEALTH AND SAFETY
Purpose
The goal of the Employee Health and Safety Code of Management Practices is to protect and promote the
health and safety of people working at or visiting member company work sites.
To achieve this goal, the Code provides Management Practices designed to continuously improve work
site health and safety. These practices provide a multidisciplinary means to identify and assess hazards,
prevent unsafe acts and conditions, maintain and improve employee health, and foster communication
on health and safety issues.
Implementation of the Employee Health and Safety Code, together with other Codes of Management
Practices, can enable member companies to operate in a manner that further protects and promotes the
health and safety of employees, contractors, and the public, and protects the environment.
Implementation of the Code helps achieve several of the Responsible Care® Guiding Principles:

considerations for all new and existing products and processes.
• To operate our facilities in a manner that protects the environment and the health
and safety if our employees and the public.
• To support education and research on the health, safety and environmental effects of our products
and processes
Each member company shall have an ongoing occupational health and safety program that includes:
Program Management
1. Commitment by all levels of management to protecting and promoting the health and safety of
people working at or visiting member company work sites, through: published policies;
accountability for implementation; and provision of sufficient resources, including qualified
health and safety personnel.
2. Opportunities for employees to participate in developing, implementing, and reviewing health

and safety programs.
3. Provisions, including selection criteria, to confirm that on-site contractors’ programs are
consistent with applicable Management Practices of this Code.
4. Written, up-to-date health and safety programs and procedures appropriate to the facility.
5. Means to verify that health and safety programs and procedures are effective and that actual
practices are consistent with these programs and procedures.
6. Systems for maintaining records and analyzing data to evaluate health and safety performance,
determine trends, and identify areas for improvement.
Identification and Evaluation
7. Methods to identify and evaluate potential health and safety hazards in planned or existing
facilities, including facilities to be modified.
8. Exposure assessments and safety analyses to evaluate health and safety hazards to employees
from processes; equipment; potentially hazardous chemical, physical, or biological agents; or
other work site conditions.
9. Health assessments to determine employee medical fitness for specific job tasks.
10. Employee occupational medical surveillance programs tailored to work site hazards.
Prevention and Control
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.
12. Systems to verify that health and safety equipment is properly selected, maintained, and used.
13. Preventive maintenance and housekeeping programs to maintain the safety of facilities, tools,
and equipment.
14. Timely investigation of work site illnesses, injuries, and incidents; corrective actions to prevent
recurrence; and evaluation of the effectiveness of corrective actions taken.
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.
Communications and Training
17. Communication of health and safety information that is relevant to specific job tasks and the
work site.
18. Health and safety training programs, including documentation of these programs, and methods
to evaluate the effectiveness of both training and communications activities.
PRODUCT STEWARDSHIP
Purpose and Scope
The purpose of the Product Stewardship Code of Management Practices is to make

health, safety and environmental protection an integral part of designing,
manufacturing, marketing, distributing, using, recycling and disposing of our products.
The Code provides guidance as well as a means to measure continuous improvement in
the practice of product stewardship.
The scope of the Code covers all stages of a product's life. Successful implementation is
a shared responsibility. Everyone involved with the product has responsibilities to
address society's interest in a healthy environment and in products that can be used
safely. All employers are responsible for providing a safe workplace, and all who use
and handle products must follow safe and environmentally sound practices.
The Code recognizes that each company must exercise independent judgment and
discretion to successfully apply the Code to its products, customers and business.
Implementation of the Code promotes achievement of several of the Responsible Care«

Guiding Principles:

considerations for all new and existing products and processes;
• To provide chemicals that can be manufactured, transported, used and disposed of

safely;
• To support education and research on the health safety and environmental effects of
our products and processes;
• To work with customers, carriers, suppliers, distributors and contractors to foster

the safe use, transport and disposal of chemicals;
• To provide information on health or environmental risks and pursue protective

measures for employees, the public and other key stakeholders;
• To practice Responsible Care® by encouraging and assisting others to adhere to
these principles and practices.
Each company shall have an ongoing product stewardship process that:
Management Leadership and Commitment
1. LEADERSHIP: Demonstrates senior management leadership through written policy, active

participation and communication.
2. ACCOUNTABILITY and PERFORMANCE MEASUREMENT: Establishes goals and

responsibilities for implementing product stewardship throughout the organization. Measures
performance against these goals.
3. RESOURCES: Commits resources necessary to implement and maintain product stewardship

practices.
Information and Characterization
4. HEALTH, SAFETY and ENVIRONMENTAL INFORMATION: Establishes and maintains

information on health, safety, and environmental hazards and reasonably foreseeable
exposures from new and existing products.
5. PRODUCT RISK CHARACTERIZATION: Characterizes new and existing products with

respect to their risk using information about health, safety, and environmental hazards and
reasonably foreseeable exposures. Establishes a system that initiates re-evaluation.
Risk Management
6. RISK-MANAGEMENT SYSTEM: Establishes a system to identify, document, and implement

health, safety and environmental risk-management actions appropriate to the product risk.
7. PRODUCT and PROCESS DESIGN and IMPROVEMENT: Establishes and maintains a system
that makes health, safety and environmental impactsùincluding the use of energy and natural
resourcesùkey considerations in designing, developing and improving products and processes.
8. EMPLOYEE EDUCATION and PRODUCT USE FEEDBACK: Educates and trains employees,
based on job function, on the proper handling, recycling, use, and disposal of products and
known product uses. Implements a system that encourages employees to feed back
information on new uses, identified misuses or adverse effects for use in product risk
characterization.
9. CONTRACT MANUFACTURERS: Selects contract manufacturers who employ appropriate
practices for health, safety and environmental protection for the operations under contract, or
works with contract manufacturers to help them implement such practices. Provides
information and guidance appropriate to the product and process risk to foster proper
handling, use, recycling and disposal. Periodically reviews performance of contract
manufacturers.
10. SUPPLIERS: Requires suppliers to provide appropriate health, safety and environmental
information and guidance on their products. Factors adherence to sound health, safety, and
environmental principles, such as those contained in Responsible Care« into procurement
decisions.
11. DISTRIBUTORS: Provides health, safety and environmental information to distributors.

Commensurate with product risk, selects, works with and periodically reviews distributors to
foster proper use, handling, recycling, disposal and transmittal of appropriate information to
downstream users. When a company identifies improper practices involving a product, it will
work with the distributor to improve those practices. If, in the company’s independent
judgment, improvement is not evident, then the company should take further measures -- up to
and including termination of the business relationship. This Management Practice should be
implemented in conjunction with the Distribution Code of Management Practices.
12. CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS: Provides health, safety and
environmental information to direct product receivers. Commensurate with product risk,
works with them to foster proper use, handling, recycling, disposal, and transmittal of
appropriate information to downstream users. When a company identifies improper practices
involving a product, it will work with the product receiver to improve those practices. If, in the
company’s independent judgment, improvement is not evident, then the company should take
further measures -- up to and including termination of product sale.
Relationship to Other Codes of Management Practices
This code complements, and should be implemented in conjunction with, current and future Codes of
Management Practices.

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Responsible Care 14001

 American Chemistry Council 2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

This Guidance Document can be used by Responsible Care 14001 auditors or by

• Responsible Care® 14001 Management System Technical Specification – this

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

In the setting of environmental, health and safety policy does

Ask for copies of policies. Are they posted?

Example: A chemical company that is a subsidiary of a

Looking for review against peers.

ACC: Doc. 2.0 Responsible Care® 14001:2002

Are the objectives and targets consistent with the

Have roles, responsibility and authorities been defined,

This is an important element of the standard for senior

ACC: Doc. 2.0 Responsible Care® 14001:2002

1.2 (continued) Guidance (continued)

Follow up questions could be:

There is a subsequent element (2.3) related to maintaining

ACC: Doc. 2.0 Responsible Care® 14001:2002

1.3 (continued) PP1- A clear commitment

Philosophically, Responsible Care considers compliance with

ACC: Doc. 2.0 Responsible Care® 14001:2002

This might be covered above but again needs to be explicitly

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

There is a need to distinguish between an organization’s

ACC: Doc. 2.0 Responsible Care® 14001:2002

2.1 (continued) PP3 Evaluation, sufficient

ACC: Doc. 2.0 Responsible Care® 14001:2002

2.1 (continued) PS5- Characterizes new

Look for processes for keeping track of federal, state, and

Regulator or legislator lobbying is not what the auditor should

ACC: Doc. 2.0 Responsible Care® 14001:2002

Look for a business planning process for resource allocation

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

2.5 (continued) Has top management appointed a management

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

Here, the focus should be the integration of EHS and

Also, look for a network of Responsible Care Code

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

3.2 (continued) PS8 - Educates and

ACC: Doc. 2.0 Responsible Care® 14001:2002

This element addresses employee involvement in the

As a follow up, ask if employees are involved with

Auditors should focus on an organization’s hourly or shop

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

Look for participation in mutual assistance networks, such as

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

ACC: Doc. 2.0 Responsible Care® 14001:2002

3.8 (continued) PS9 - Selects contract

ACC: Doc. 2.0 Responsible Care® 14001:2002

This element is ISO-specific and not found directly in