Professional Documents
Culture Documents
IMPCAS
Container Freight Station Audit Report
Marine Pack Cargo
Management Questionnaire
Seconed Edition
October 2012
CFS Cover
Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute
International Marine Packed Cargo Audit Scheme
All rights are reserved. Except for the normal review purposes no part of this document may
be reproduced, utilised, stored in any retrieval system or transmitted in form or by any means
electronically or mechanically, include photocopying, recording or by information, storage or
retrieval system without the written permission of Chemical Distribution Institute (CDI)
ACKNOWLEDGEMENT
The original material contained in this document was prepared by European Chemical
Industry Council (CEFIC) which is gratefully acknowledged.
The contribution made by all members of the IMPCAS Technical Committee in the
preparation of this the Second Edition of the Container Freight Station Audit Report.
While this report has been developed using the best information currently available, it is
intended to be used entirely at the users own risk. No responsibility is accepted by the
Chemical Distribution Institute (CDI) or any other person, firm, corporation or organisation
who or which has been in any way concerned with the furnishing of information or data, the
compilation or any translation, supply or sale of this report, for the accuracy of any information
given herein or for any omission here from or for any consequences whatsoever resulting
directly or indirectly from information contained herein even if caused by failure to exercise
reasonable care.
CFS Intro
Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 2
IMPCAS
Container Freight Station Questionnaire
List of Abbreviations
Index
Introduction
List Of Abbreviations
A. General Information
B. Audit Summary
Sect 3 Security
3.1 Security Standards and Procedures
3.2 Site Security
3.3 Security Training
CFS Intro
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IMPCAS
Container Freight Station Questionnaire
List of Abbreviations
Sect 6 Equipment
6.1 Equipment Specification
6.2 Equipment Inspection and Maintenance (Service)
6.3 Equipment Inspection, Maintenance, and Calibration
6.4 Equipment of Partners
CFS Intro
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IMPCAS
Container Freight Station
List of Abbreviations
Preface
Chemical Companies use mainly third party Logistics Service Providers, often referred to as
the "distribution industry", to store, handle and transport their feedstocks, intermediates and
finished products between their manufacturing plants and end-use customers.
There is a need for Chemical Companies to be assured that these activities are carried out
with due regard for safety and quality, protection of employees, the public and the
environment.
In the past the assurance was gained by individual chemical companies undertaking periodic
audits of their logistic service providers. This was a very fragmented approach that led to a
multiplicity of auditing programmers, high costs and inefficiency for the industry.
In the early 1990's, chemical companies recognised the need to take a fresh look at the
safety, quality and environmental aspects of supplier assurance. Initiatives begun then have
evolved and developed into schemes such as that for marine bulk operations, administered
by CDI (Chemical Distribution Institute), the Safety and Quality Assessment Scheme (SQAS)
in Europe e.g. for Road Haulage activities, several protocols developed by ACC (American
Chemistry Council). These schemes offer a cost effective mechanism for monitoring the
safety, quality and environmental performance of logistic service providers. In addition, the
documentation developed has led to a better understanding of the risks involved, and to the
establishment of more efficient safety management systems.
In 1990 both the European Chemical Industry Council (CEFIC) and the American Chemical
Council (ACC) independently discussed how to efficiently assess ship operators transporting
chemical cargoes in ISO tanks, containers or trailers. The protocols subsequently developed
enable logistic service provides to have their quality, safety and environmental management
systems assessed in a uniform manner, and to avoid multiple assessments by different
interested parties. Assessment results can then be offered to any client and used in the
selection of suitable service providers and for defining any areas of improvement. Although
this assessment system does not guarantee the safety, quality or value of the company, the
system will provide useful feedback directly to the service provider on the strengths and
weaknesses identified during the assessment results thereby creating/strengthening a
parternership of mutual benefit, within which the key safety and quality principles are
practiced.
In 2000, the CEFIC “Ship” and “Shipping Company” questionnaires were revised in close co-
operation with the International Chamber of Shipping (ICS) and the International Association
of Classification Societies (IACS), to take account of existing safety and quality management
systems used in the shipping industry: namely International Safety Management (ISM) Code
and ISO 9001:2000.
In 2001, these protocols were merged into global documents, combining the best of the
CEFIC and ACC protocols. The development of global documents for the assessment of
other elements of the MPC supply chain is being anticipated in the future. Meanwhile, current
protocols for these other elements like freight forwarding, transfer terminals etcetera remain
valid on a regional basis.
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IMPCAS
Container Freight Station Questionnaire
Introduction
Background
The Questionnaire has been developed as part of the IMPCAS Container Freight Station
Management “Safety and Quality Assessment System for Marine Pack Cargo Operations”
The aim of the Questionnaire is to give an accurate assessment of the MPC Operator at the
time the audit is carried out. The Questionnaire is essentially a safety, quality and
environment protection assessment of a MPC Operator, its operations and personnel.
The Questionnaire does not attempt to pass or fail the MPC Operator for any particular
purpose but rather to give an assessment of performance at the time of the audit.
The Auditor
The highest standards of ethical behaviour are expected from IMPCAS Auditors. The findings
presented in the Questionnaire are to be regarded as confidential and the property of the
MPC Operator and on no account shall the Auditor discuss the contents of the report with any
third party.
The Auditor should be an observer only and should not interfere or become involved in
working practices of the MPC Operator or be a party in any discussion between the MPC
operator, customer, local authorities, etc.
The Auditor shall not operate any equipment or advise any on any operational or
constructional matters or give any advice on how a particular non compliance or observation
may be corrected.
A courteous and considerate approach is expected of the Auditor in all dealings with MPC
Operator’s personnel. The Auditor should take care to ensure that his actions do not in any
way delay or interfere with normal operation of the MPC Operator.
Additional columns indictate whether it is Mandatory (M) or and Industry (I) requirement, and
if it is applicable for compliance with Responsible Care® (RC) and CUSTOMER – TRADE
PARTNERSHIP AGAINST TERRORISM (C-TPAT)
It should be noted that the M questions have increased significantly to (a) cater for changes in
legislation and (b) additional requirements of the IMPCAS Technical Committee who felt it
necessary to raise the level of industry norm to a mandatory requirement thereby improving
QHSSE within the logistics supply chain.
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IMPCAS
Container Freight Station Questionnaire
Introduction
Specific Questions,
All Questions Core and Specific are to be answered “Yes” or “No”, with provision for a “N/A”
answer when a facility or piece of equipment does not exist.
Questions within the Questionnaire which clearly do not apply to the MPC Operator should be
marked as N/A but Auditor to make comment.
A “No” answer to a question does not necessarily imply that the MPC Operator is not in
compliance. An explanation is required, and comment must be made in the report.
Audit procedures
An audit shall not normally be carried out during the night. The only exception to this is when
special arrangements have been made with the MPC Operator prior to the Auditor arriving at
the location.
The Auditor is expected to set a good example with respect to his own safety procedures
during the period of the audit. The Auditor should wear, as appropriate for the location,
protective clothing and equipment including boiler suit, safety helmet, safety shoes, safety
gloves, ear protectors and goggles / safety glasses.
The MPC Operator’s safety procedures and notices displayed on site must be complied with
by the Auditor. The Auditor shall not enter restricted areas unless the Manager's permission
has been obtained and any relevant permits / checklists have been completed correctly. An
Auditor shall not enter an enclosed space unless entry procedures are fully complied with.
Opening meeting
On arriving at the location, the Auditor shall identify himself / herself to the Manager (or his
representative) and outline the objectives and requirements of the audit. The Auditor and the
Manager (or his representative) should agree the sequence for the audit. The audit should
be planned and carried out in a manner which will not conflict with the safe operation of the
site. The Auditor should establish when key personnel will be available to assist with the audit.
During the audit, it is recommended that the Auditor is accompanied at all times by a
responsible and suitably qualified person(s), nominated by the Manager.
Proper planning at the Opening Meeting will enable the audit to be carried out efficiently and
with the minimum of disruption to the normal working of the site.
The Audit
With a site in operation, some areas may not be capable of inspection, e.g. restricted loading
bays. When any question is not addressed due to operational reasons, the N/A check box
should be marked and a note made in the relevant Remarks section.
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IMPCAS
Container Freight Station Questionnaire
Introduction
Items in the report which are marked "Information only" and require data to be entered, must
be completed.
If certain items of information are not available, a comment shall be made in the relevant
Remarks section.
With the exception of "familiarity" type questions which by their nature are subjective, answers
to all other questions must be based on objective evidence. Objective evidence is defined as
qualitative or quantitative information, records or statements of fact which is based on
observation, measurement or test and which can be verified.
The assurance of site staff should not be accepted by the Auditor as compliance with a
particular question, without objective evidence being produced to support their assertions.
An Auditor may request the demonstration or test of a particular piece of equipment. Should
the request be refused, then this should be noted in the relevant Remarks section, together
with the reason for refusal.
Requests for a test of equipment should not be made where this will result in a major
disruption to the sites normal operations. i.e. stopping operations, blackout etc.
Closing meeting
On completion of the audit, the Auditor will hold a closing meeting with the Manager (or his
representative). At the closing meeting the Auditor shall provide the Manager with a copy of
the record of negative answers and summary of observation and remarks.
The Auditor shall discuss with the Manager (or his representative) the answers given in the
Questionnaire and if requested to do so, explain how the answers have been determined.
Should a "No" answer or observation be contested, then the Auditor shall give the Manager
the opportunity to produce objective evidence to satisfy the requirement. If satisfactory
evidence of compliance is produced, then the answer to the question may be amended.
Answers to questions, should not be amended after the Auditor leaves the site.
The Manager should be requested to sign for the summary of observation and remarks. The
Manager's signature is for receipt only and does not infer that the Manager agrees with
assessment or remarks.
The Manager (or his representative), must be given the opportunity to comment in writing on
the contents of the Questionnaire. Any written comments from the Manager (or his
representative) will be entered to the database by the Auditor.
The Audit does not result in a pass or fail. The Questionnaire is for consideration by potential
customers only. The Auditor shall not make any recommendations for the correction of any
items marked as "No" in the Questionnaire, nor indicate to the Manager, or any other person,
the standard of the location or the possible eventual outcome of the audit.
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IMPCAS
Container Freight Station Questionnaire
Introduction
During, or on completion of the audit, the Auditor shall enter all the Audit data (together with
any comments from the Manager), into his computer terminal and then up-load the report to
the IMPCAS database in accordance with the procedures governing control of the IMPCAS
database system.
The use of the electronic database provides a level of security for the Questionnaire data
which is easily compromised if information is faxed or mailed to uncontrolled third parties.
The Auditor is responsible for the security of the Questionnaire data between the time of
carrying out the audit and uploading the data to the IMPCAS database. The Auditor shall
ensure that a back up of the Questionnaire Data is available in the event that the original
Questionnaire Data is lost prior to uploading to the IMPCAS database.
Auditors are required to ensure that:
- All laptops and portable data storage devices are password protected.
- All MS Excel and pdf files are deleted from laptops and portable data storage devices
after conveyance of the document to the relevant party.
- Historic report data is only retained on office hard drives in the client.rep file format.
After uploading Questionnaire Data to the IMPCAS database all hard copy Questionnaire data
shall be retained by the Auditor for a period of the active life of the report.
The Auditor will be advised by IMPCAS if hard copy Questionnaire data is to be forwarded to
IMPCAS for assessment or other purposes.
Documentation
IMPCAS may print and store hard copies of the audit results in a central archive but will not
provide copies of the reports to interested parties unless authorised in writing by the
respective of MPC Operator management.
It remains the MPC Operator’s prerogative to allow IMPCAS to provide copies of the
completed IMPCAS documentation to any interested (potential) clients. The operators
themselves will not distribute the reports to customers.
The Auditor should return any advance documents received to the Operators Coordinator
unless written consent is achieved to do otherwise.
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IMPCAS
Container Freight Station Questionnaire
List of Abbreviations
This List of Abbreviations provides a summary of the standard acronyms and abbreviations.
c Core Question
CDI Chemical Distribution Institute
CEFIC European Chemical Industry Council
CMR Convention Merchandise Routier
CTU Cargo Transport Units
D Desired
D&A Drug and Alcohol
DGA Dangerous Goods Advisor
GN Guidance Note
I Industry
ICS International Chamber of Shipping
IMDG International Maritime Dangerous Goods (Code)
IMPCAS International Marine Packed Cargo Audit Scheme
ISM International Safety Management Code (IMO)
ISO International Standards Organization
M Mandatory
MPC Marine Pack Cargo
RC Responsible Care
RID Regulations Concerning the international carriage of dangerous goods by rail.
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Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 10
Section A Container Freight Station GENERAL INFORMATION
Audited By :- __________________________________________________(Name)
Company information :-
Address:-
Tel:-_____________________________ Fax:-____________________________
Contact Person(s) :-
Name :-
E-Mail :-
Name :-
E-Mail :-
Branch Offices:-
Address:-
Address:-
Audit Report For simplification of the Audit process, Core questions have been identified with the
letter "c" alongside the question number. Any company that has undertaken an CDI-
Impcas audit for Freight Forwarder/Container Freight Station/Ship Agent modules
within the CDI-impcas scheme and the audit report is dated no more than three calendar
months before this specific audit and has complied with the requirements of the CDI-
impcas standards, need not answer Core "c" questions.
For those international companies who have operating offices around the world, the
application of the CDI-Impcas Container Freight Station Management Questionnaire is
as set out hereunder.
The company must have a Core and Specific pack audit (every question) conducted by
an authorised CDI-Impcas auditor, if the audited company then chooses to have a
further operating centre audited within 6 months in the same region then
Core questions of the audit are NOT REQUIRED to be completed, only the Specific
questions need to be answered.
If the same company has operating centres in different parts of the world then for each
country/region audited the above applies.
The contents of this audit report are based on a visual assessment of the site as found at
the time of the audit.
The report is given in good faith, without prejudice and any responsibility is limited to
the exercise of reasonable care.
Terms
The term “CTU means “CARGO TRANSPORT UNIT” and is used throughout as a
generic term to describe all types of cargo carrying equipment such as containers, tank
containers, flatracks, swap bodies, vehicles, rail wagons, road tankers etc.
The term “CTU Packing/unpacking” means the act of placing cargo in or on any type of
CTU, or removing cargo from a CTU.
Definition
Container Freight Station Services means services of any kind relating to the carriage
(performed by single mode or multimodal transport means), consolidation, storage,
handling, packing or distribution of the Goods as well as ancillary and advisory services
in connection therewith, including but not limited to customs and fiscal matters,
declaring the Goods for official purposes, procuring insurance of the Goods and
collecting or procuring payment or documents relating to the Goods. Freight
Forwarding Services also include logistical services with modern information and
communication technology in connection with the carriage, handling or storage of the
Goods, and de facto total supply chain management"
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Section B Container Freight Station Audit Summary
IMPCAS
Ref Closing Meeting, Observations and Remarks
CFS Summary
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Section B Container Freight Station Audit Summary
IMPCAS
Ref Closing Meeting, Observations and Remarks
CFS Summary
Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 16
Container Freight Station Management Summary Guidance Notes
Section B Guidance Notes
Closing Meeting, Observations and Remarks
The Auditor shall request that the Manager signs for the form to confirm
its receipt. Should the Manager decline to sign for the receipt of the form
then this shall be noted on the form by the Auditor.
1.1.2.5 c Has the company formally appointed a DGA (Dangerous Goods Advisor) who meets M RC
and is suitability qualified to advise on legal requirements?
1.1.2.6 c Does the Dangerous Goods Advisor produce an annual report that includes M RC
investigation of incidents to Management ?
1.2.1 Recruitment
1.2.1.1 Is there a written procedure which takes the following items into account :
1.2.1.1a c - previous employment and relevant experience ? I C-TPAT
1.2.1.1b c - relevant competence / education ? I C-TPAT
1.2.1.1c c - temporary staff/drivers ? I C-TPAT
1.2.1.1d c - are job descriptions issued on employment to new employees ? I C-TPAT
1.2.1.2 c Are all operating personnel (drivers, operators, etc.) given a periodic medical M
examination dependent on the risks to which they are exposed ?
1.2.1.3 c Is there a written disciplinary procedure and are records retained ? I
1.2.2 Training
1.2.2.1 c Is there induction training for newly appointed managers, supervisors and I RC
operational personnel ?
1.2.2.2 c Is there a process for reviewing the training requirements of managers, supervisors I RC
and operational personnel, on at least an annual basis ?
1.2.2.3 Are the following subjects covered in the training programme for operational
personnel :
1.2.2.3a c - personal responsibility ? I RC
1.2.2.3b c - customer relationship ? I RC
1.2.2.3c c - media / crisis management training ? I RC
1.2.2.3d c - security awareness proportionate to the risk and their role within the business ? I RC
1.2.2.3e c - legal requirements ? I RC
1.2.2.3f c - specific work instructions ? I RC
1.2.2.3g c - incident reporting, investigation and analysis ? I RC
1.2.2.3h c - dangerous goods handling to meet updated legislation ? I RC
1.2.2.3i c - ratio filling of tanks ? M RC
1.2.2.3j c - specific supplier product or handling needs ? M RC
1.2.2.3k c - handling and use of Personal Safety Equipment ? I RC
1.2.2.3l c - company emergency procedures ? M RC
1.2.2.3m c - spill prevention and control ? I RC
1.2.2.3n c - Behaviour Based Safety (BBS) principles ? or similar safety based programme ? I RC
1.2.2.3o c - customs handling ? I RC
1.2.2.3p - correct storage and handling of materials ? I RC
1.2.2.3q - customs regulation ? I RC
1.2.2.3r - lashing and securing standards and methods for container’s packed for I RC
applicable mode of transport, including the use of securing materials?
1.2.2.3s - dangerous goods segregation requirements of the IMDG Code for container’s I RC
packed for marine transport?
1.2.2.4 c Is a first aid training programme defined for identified persons and implemented ? M RC
1.2.2.5 c Are records maintained of who has been trained in what subjects ? I RC
1.2.2.6 c Is there a formal transfer of skills programme in place ? I RC
1.2.2.7 c Are refresher trainings carried out ? I RC
1.3.1.1k - quantity ? I RC
1.3.1.1l - Incidents causing delays to schedule ? I RC
1.3.1.1m - damage occurrence? I RC
1.3.2.2 c Is there a process in place for the analysis of data to identify trends for Environment I RC
to measure and to improve the output of emissions?
1.3.2.3 c Has the Safety, Health, Environment and Security Plan of the company been I RC
reviewed against the applicable Responsible Care Programme ?
1.3.2.4 c Does the company promote the principles of Responsible Care to logistic partners? I RC
1.3.2.5 c Are specific SHEQ&S objectives set and monitored and is an action plan in place to I RC
achieve these objectives?
1.3.2.6 c Are specific QHSSE objectives set and monitored ? I RC
1.3.2.7 c Are annual targets set for improvement of the company's performance on QHSSE I RC
and is there an action plan how to achieve this improvement ?
1.3.2.8 c Is the effectiveness of the corrective and preventative actions based on the results I RC
of the trend analysis, monitored and documented ?
1.4.1.2 c Does senior management monitor progress versus targets on SHEQ&S matters at I C-TPAT RC
every management meeting?
1.4.1.3 c Are safety walk abouts carried out and documented by appropriate managers on a I RC
periodical basis?
1.4.2 Internal Communication
1.4.2.1 c Is there evidence that learning's on QHSSE issues are shared with the workforce ? I RC
1.5.1 Insurance
1.5.1.1 c Does the company's insurance cover its contractual and legal liabilities related to the
loss, damage of carried/handled products for third party liability, and is the
insurance in compliance with legal and customer requirements, for following
elements :
2.2.1.5 Are the following items although not restricted to issued to employees:-
2.2.1.5a - protective gloves ? I RC
2.2.2.8e - Does the company have transhipment facilities for all products? I RC
2.2.2.8f - Does the company have procedures for dealing with damaged container's? I RC
2.2.3 Off-site Emergency Preparedness and Response
2.2.3.1 Does the company have appropriate twenty-four hour emergency plans consistent I RC
with governing regulations for all off-site activities.
2.2.3.2 Does this off-site written plan contain a list of the different parties to be informed I C-TPAT RC
with their contact details (customers, authorities)?
2.3.10 Is there a policy for safely removing debris and cargo residues from containers prior I RC
to loading ?
2.3.11 Is there a policy for identification of residue found in nominally empty container's ? I RC
2.3.12 Is there a policy for removal of dangerous goods residue or rejection of containers I RC
contaminated with dangerous goods or non-hazardous residue? (See also section
2.3.13 2.4.5
Is Waste
there Management)
a policy for checking potential fumigation levels in loaded containers prior to I RC
entry?
2.4 Environment
2.4.1 c Has the company identified the applicable environmental regulations relevant to its M RC
2.4.2 c Has the company identified the applicable impacts and aspects of its operation ? I RC
2.4.3 c Is all material and waste, which are covered by regulations, stored and disposed of M RC
2.4.4 c Are waste disposal records retained as per legal requirements ? M RC
2.4.5 c Does the company have a waste reduction strategy ? I RC
3.1.1 c Has the company appointed a person with appropriate qualifications and I
competence, as the person responsible for security ?
3.1.2 c Has the company developed a security plan which covers ADR/IMDG requirements M C-TPAT
and security arrangements as defined in ISO/PAS 28000, WCO Framework of
Standards ?
3.1.3 Does the company Security Plan include :
3.1.3a c - a regular review of the operations and an assessment of potential vulnerabilities I C-TPAT
3.1.3b c - measures to reduce security risk ? I
3.1.3c c - reporting of and dealing with security threats, breaches of security, and security I C-TPAT
incidents ?
3.1.3d c - testing/evaluation of the company security provisions are reviewed on a yearly I C-TPAT
basis ?
3.2 Site security
3.2.1 c Is the site properly secured with fences and gates, well lit and not accessible to the I C-TPAT
general public ?
3.2.2 c Is there a system to monitor entry and movement of all personnel and visitors on site I C-TPAT
through positive identification ?
3.2.3 c Is there a procedure in place, requiring a.o. documented periodical inspections, to I C-TPAT
identify breaches in the security of the buildings ?
3.2.4 c Is there a system to monitor entry and movement of vehicles on site ? I
3.2.5 c Is there a system to protect computer information on customers, products and I C-TPAT
3.2.6 operations
c Is ?
the site manned 24/7 or adequate security achieved by other means ? I
3.2.7 Is there an Access Device Control in place (Badges, Keys, etc.) I C-TPAT
3.2.8 Does the site have video surveillance system to monitor activity in to I C-TPAT
site/offices/warehouse?
3.2.9 Is there a security alarm system in place covering accesses to I C-TPAT
site/offices/warehouse?
4.6.16 c Does the company actively participate in the development, implementation and I RC
maintenance of community emergency preparedness plans?
4.6.17 c Does the company Emergency Plan make consideration for community recovery I RC
4.6.17a c - Is there evidence to show that community recovery needs are periodically I RC
reviewed, particularly for new products being stored?
5.2.2 Does the company follow-up the service providers' actions to ensure achievement of I C-TPAT RC
the targets ?
5.5.1.2 Is there a procedure and register in place for periodic testing of flexible hoses where
in use, which includes the following elements :
5.5.1.2a - compatibility of the hose and cargo ? I RC
5.5.1.2b - identification of different types and numbering ? I RC
5.5.1.2c - periodic inspection and recording of results ? I RC
5.5.1.2d - periodic pressure testing ? I RC
5.5.2 Performance monitoring process
5.5.2.1 Has the company a documented process for the evaluation and performance I RC
monitoring of all its service partners ?
5.5.2.2 Does the company use CDI/SQAS protocols to evaluate sub contractors ? I
5.5.2.3 Is a joint improvement plan implemented and monitored ? I
5.5.2.4 Does the company have authority to perform on-site QHSSE assessments and is I
this contained in the agreement ?
5.5.2.5 Does the company retain evidence of compliance with the performance criteria :
5.5.2.5a - was verified before the agreement was signed with each subcontractor, and I
repeated regularly ?
5.5.2.5b - is followed-up on a regular basis through dialogue and improvement action I
programmes with the subcontractors ?
5.5.2.6 Are scheduled meetings held with selected subcontractors at management level to I C-TPAT RC
review objectives and performance ?
6.2.1.2b - to remove from service equipment with faults affecting safety and integrity ? I RC
6.2.1.2c - to remove from service equipment that is overdue for inspection, examination or I RC
test ?
6.2.1.2d - to rectify defects and record all maintenance and repairs, including details of I RC
items replaced and any follow-up actions ?
6.2.2 Lifting Equipment
6.2.2.1 Is the lifting equipment which is in use (e.g. cranes, straddle carriers, etc.)
6.2.2.1a - SWL (Safe Working Load) certified? M RC
6.2.3.2b - to remove from service equipment with faults affecting safety and integrity ? M
6.2.3.2c - to remove from service equipment that is overdue for inspection, examination or I
6.2.3.2d - to rectify defects and record all maintenance and repairs, including details of I
items replaced and any follow-up actions ?
6.2.3.3 Is control exercised over the release and use of equipment which is overdue for I
inspection ?
6.4.2 Does the company have evidence that selected subcontractors have a documented I
programme in place for preventive inspection and maintenance of their equipment ?
6.4.3 Does the company have evidence that selected subcontractors have a program in I
place that their vehicles and their fittings are serviced on a regular basis ?
6.4.4 Does the company have evidence that selected subcontractors are carrying out M
timely statutory inspections of the units and trailers ?
6.4.5 Does the company have evidence that selected subcontractors are carrying out M
calibration in accordance with legislation, for designated critical equipment, when
applicable ?
7.0
Responsible Care Management System (RCMS) Questions for US Audits
7.1 Do the company policy statements make clear reference to Security? I RC
7.2 Are the company policy statements communicated to stakeholders and members of I RC
the public?
7.3 Are the company policy statements relevant to the nature, scale and impact of the I RC
organizations operations?
7.4 Do the company policy statements drive setting Responsible Care/EHSS objectives I RC
and targets?
7.5 Do the company policy statements commit to comply with other Responsible Care I RC
related requirements?
7.6 Do the company policy statements promote openness with stakeholders? I RC
7.7 Does the management system require periodic review to assure that Risk I RC
Assessment is maintained and up to date ?
7.8 Is there a system to detect and review changes in ''existing chemical products'' I RC
7.9 shipped?
Does a documented system exist to ensure the distribution of technical information I RC
within the company ?
7.9.1 Are managers and employees aware of the system? I RC
7.10.2 contractors? I RC
7.10.3 customers? I RC
7.10.4 distributors? I RC
7.10.5 suppliers? I RC
7.12 Do the established Responsible Care/EHSS objectives and targets take into I RC
consideration the stakeholder perspectives?
7.13 Are the established Responsible Care/EHSS objectives and targets in line with the I RC
prioritized risks and hazards?
7.14 Are the established Responsible Care/EHSS objectives and targets within the I RC
context of the policy statement?
7.15 Does the management system allow for verification that resources are sufficient and I RC
appropriately allocated to meet Responsible Care goals, objectives and targets?
7.16 Is there clear evidence that RCMS is integrated into the business management I RC
7.17 process?
Does the RCMS include a mechanism to seek public input regarding operations? I RC
7.18 Is there a system to manage the safe and secure use of chemicals? I RC
7.19 Is there evidence of considerations for EHSS and resource conservation for new I RC
and existing processes?
7.21 Are protective measures pursued concerning EHSS risks to the public? I RC
7.23 Are protective measures pursued concerning EHSS risks to other stakeholders? I RC
7.24 Is there a system to work with and to foster the safe use, transport and disposal of
7.24.1 chemicals with:
customers? I RC
7.24.2 carriers? I RC
7.24.3 suppliers? I RC
7.24.4 distributors? I RC
7.24.5 contractors? I RC
7.25 Do plans and procedures in place for potential emergencies and incidents consider I RC
normal and abnormal operating conditions?
7.32 Do key personnel have sufficient training and resources for implementation? I RC
7.34 Do the internal audits of the management system address regulatory compliance? I RC
7.35 Does the selection process and performance assessment of contractors address I RC
EHSS?
7.36 Is there a system to qualify and select waste disposal contractors that includes I RC
EHS?
7.37 Is there a system to track and review waste disposal contractors EHS performance? I RC
7.38 Is there a system to qualify and select other commercial partners that includes EHS? I RC
7.39 Is there a system to track and review other commercial partners EHS performance? I RC
7.40 Is there a system to complete corrective and preventative actions resulting from I RC
incidents and accidents?
7.41 Is there a system to share key incident and accident findings with relevant I RC
stakeholders?
7.42 Are Senior management reviews of other RCMS elements conducted as scheduled I RC
7.43 Is there a system to assure that the organization is meeting it's Responsible Care I RC
7.44 Is RCMS performance periodically reported to all stakeholders? I RC
8.1.2 Does the company implement measures to ensure the security of the products and
transport information throughout the chain of its service partners, including at :
8.1.3 Is the handover/transfer of security with the associated responsibilities signed and M
documented ?
Security during intermodal transport moves
8.2.1 Does each company employee and subcontractor employee carry with them means M C-TPAT
of identification, which includes their photograph ?
8.2.2 Are all fully loaded containers containing sealed and seal numbers provided I
separately (electronic or on paper) ?
8.2.3 Are seal discrepancies for investigated thoroughly, the shipment rejected if I
necessary, security personnel notified and extreme care taken if there is evidence of
seal tampering ?
8.3 Legal requirements for High Consequence Dangerous Goods (HCDG) :
8.3.1 Does the security plan include all associated areas as defined in Section 1.4 of M
IMDG High Consequence Dangerous Goods (HCDG)?
8.3.2 Does the security plan include the following elements:-
8.3.2a - appointment of a responsible, competent and qualified person for security? M RC
8.3.2b - does the responsible person for security report direct to management with M RC
relevant information to reduce the security risk?
8.3.2c - do the company keep records of dangerous goods or types of dangerous good M C-TPAT RC
transported?
8.3.2d - do the company at regular intervals have a general review of operations from a M C-TPAT RC
security point of view, and update procedures?
8.3.2e - is there security awareness training program for employees whose activities are M C-TPAT RC
related to the transportation of High Consequence Dangerous Goods and
recognising the security risks ?
8.3.2f - are there records of all security training undertaken kept by the employer? M RC
8.3.2g - are all employees aware they should report to the management any threat, M RC
breach of incident observed in relation to security ?
8.3.2h - do the company co-operate with customers and appropriate authorities in the M C-TPAT RC
exchanging of threat information and apply applicable security measures to
respond to security incidents?
8.4 Best practices for intermodal transport security of HCDG :
8.4.1 Does the company have measures to monitor the movement of HCDG whilst in M C-TPAT
transit ?
8.4.2 Are all fully loaded containers containing HCDGs sealed and seal numbers provided I C-TPAT
separately (electronic or on paper) ?
8.4.3 Are seal discrepancies for HCDG investigated thoroughly, the shipment rejected if I C-TPAT
necessary, security personnel notified and extreme care taken if there is evidence of
seal tampering ?
8.4.4 Is the site properly secured with internal fences in and around areas that handle I C-TPAT
HCDG ?
9.1.3 Are there comprehensive procedures at the facility including work permit
requirements, to ensure safety and to avoid exposure to hazardous materials, for
following operations :
9.2.2 Has the responsibility for the unloading/unpacking of cargo/goods been defined
between the customer and the CFS operator regarding:
9.2.2a - site access requirements at the unloading/unpacking site ? I C-TPAT RC
9.2.2b - party at unloading site to report to for unloading ? I RC
9.2.2c - authorisation to start unloading ? I RC
9.2.2d - documents accompanying the unloading process (before/during/after) ? I RC
10.2.3k - to ensure that sides and ends of the container are placarded and marked in M RC
accordance with IMDG code?
10.3 Operator Handling
10.3.1 Do written operating instructions require operators:
10.3.1a - NOT to handle damaged, leaking or stained packages, but to seek expert I
10.3.1b advise?
- NOT to load a freight container without a valid safety approval plate ? I
10.3.1c - NOT to load packages of dangerous goods which are not correctly labelled and I
marked ?
10.3.1d - NOT to load packages into a container which is wet, damaged or unclean ? I
10.4.1 Is there a drivers manual distributed to all drivers in a language they can understand I
?
10.4.2l - after loading, verification that vehicle and container have no obvious defects, I RC
leakages, cracks, missing equipment ?
10.4.2m - after loading, verification that danger labels and markings (orange plates) M RC
prescribed for the vehicles, have been affixed (IMDG code) ?
10.4.2n - compliance with route restrictions for specific products ? I RC
10.4.2o - use of wheel blocks (to avoid uncontrolled vehicle movement) ? I RC
10.4.3 Does the drivers manual contain, in addition, specific detailed instructions for
PACKAGED GOODS regarding :
10.4.3a - inspection of cargo compartment for cleanliness and potential risks (e.g. nails) ? I RC
10.4.3b - stowage and cargo securing ? I RC
10.4.3c - product compatibility and segregation ? I RC
11.1 Records
11.1.1 Are records of all transport/handling orders (receipts and deliveries) kept, including :
1.1.2.3 Seek evidence in sr., middle management communication encouraging staff and contractors to also
show leadership at that level, resulting in reports regarding HSSE metrics against HSSE target like
incidents, near misses, occupational illness case analysis. Are those also consequently discussed in
the appropriate committee(s).
1.1.2.4a-d Look for documentary evidence. If a person is formally designated, this responsibility should be
clearly described in a job description. If an external source is used, there should be clear evidence
of a contract, exchange of letters or some other form of written understanding specifying the service
to be provided, when and to whom within the Company.
1.1.2.5 All companies that are engaged in the loading, transport or unloading of dangerous goods are
required to appoint a certified Dangerous Goods Adviser (DGA). Companies may appoint an
individual within their own organisation or they may use the services of an external consultant.
Check that the Company has formally appointed an individual as Dangerous Goods Adviser by
written notification. Check the validity of the Dangerous Goods Adviser's training and certification.
1.1.2.6 Check that the Dangerous Goods Adviser produces annual report in a timely manner summarising
the Company’s activities concerning the transport of dangerous goods that is in compliance with the
legal requirements. Check that the report explicitly includes security.
1.2.1 Recruitment
1.2.1.1 There should be a written recruitment procedure. Give a score for each item (a - d) mentioned when
it is clearly specified in the procedure.
1.2.1.1a Verify a random sample from records.
1.2.1.1b Verify that the requirements of the job are consistent with the person's background, education,
experience, competence and knowledge of appropriate working languages. Where permitted by
law, verify that individuals' security background have been checked.
1.2.1.1c Check whether temporary staff are employed regularly or occasionally. In either case, the
recruitment policy should require the same criteria to be applied for temporary staff/drivers as for
permanent staff.
1.2.1.1d Verify a random sample from records.
1.2.1.2 Check for evidence. Keep in mind that the legal requirements might be different in some countries.
1.2.1.3 The disciplinary procedure should be a written one and communicated to all employees. Verify by
asking a sample of employees that they have been made aware of this procedure. Establish that the
procedure has been followed. Note access to confidential records may not be possible, but the
viewing records with seeing the names of individuals should be possible.
1.2.2 Training
1.2.2.1 Induction training at the commencement of employment provides new employees, part time staff
and contractors with important information about the core values, policies and procedures within the
organisation. Induction training can be expected to cover at least the following: Quality,
environmental, safety, safety and health and security and emergency response arrangements. There
should be induction training records showing who was trained, when, by whom and on what
subjects.
1.2.2.2 All managers, supervisors and operational personnel are expected to have formal training in subjects
related to their job and responsibilities. It is expected that the training requirements are reviewed on
at least an annual basis and actions taken to satisfy training needs.
1.2.2.3 a-s Check random samples of training records to confirm that the subjects mentioned are covered.
Training should include at minimum general requirements relating to the specific job requirements
1.2.2.4 Verify that the first aid training programme is documented and implemented (including refresher
training). This may vary by country legislation.
1.2.2.5 Check that records are complete and up-to-date.
1.2.2.6 Are there sufficient persons trained and skilled for key activities to provide cover for absences; leave,
illness etc.?
1.2.2.7 Verify from records.
1.3.1.1 This question (items a - j) only scores if there is a documented system in place for recording and
investigation, clarifying what is a non-conformance, who must report, how and to whom, who must
investigate and the process of follow-up and close out of corrective actions. These questions are
applicable for all domains such as environment, safety & health, security.
1.3.1.1a.b Accident : An unplanned event that did result in quality loss, injury, illness, or damage. Incident :
An unplanned event that could have resulted in quality loss, injury, illness, or damage
1.3.1.1f e.g. observed overdue implementation of new regulatory requirements, fines,
1.3.1.1g A situation or behaviour that did not result in quality loss, injury, illness, or damage, but has the
potential to do so.
1.3.1.3 Look for documentary evidence that appropriate immediate actions are taken following the issue of a
non-conformance report.
1.3.1.4 Look for documentary evidence that appropriate notifications are issued to the customer within
24hours.
1.3.1.5 For all non-conformances, a written report should be prepared for the responsible management and
the customer without undue delay and in accordance with an internal procedure, covering a - c. The
investigations into non-conformances should identify the immediate causes, the root causes and
recommended actions to prevent recurrence. Where appropriate and depending of the nature of the
non-conformance, recognised techniques should be used to identify the root causes e.g. cause tree
analysis. Check a few reports from the file of completed non-conformances.
1.3.2.1a-c An effective system should be in place for the recording and analysis of data, which allows
identifying trends in the number of QHSSE non-conformances. Check evidence that such a system
exists. Ask to see a summary of the trend analysis for the last year(s). If a company has already
been assessed, data should be available for the last three years, which should document continuous
improvement on the issue. If not, this question must be scored with "N".
1.3.2.2 Typically from machinery, product clean up, drumming activities, disposal of oily waste, etc.
1.3.2.5 Verify whether SHEQ&S objectives are defined and if these objectives are monitored as per defined
frequency (e.g. quarterly, annually) with actual performance data.
1.3.2.6 Verify whether QHSSE objectives are defined and if these objectives are monitored as per defined
frequency (e.g. quarterly, annually) with actual performance data.
1.3.2.7 Look for documentary evidence that annual targets have been set and that measurements of the
performance improvement against targets are being made. Also check if there is an action plan to
support and achieve the targeted improvement.
1.3.2.8 Look for documentary evidence on the effectiveness of the corrective and preventative actions
1.4.1.1a-d Check for evidence that a formal management review of the QHSSE management systems is held,
at least annually, to evaluate the overall effectiveness of these systems. In large companies, these
meetings may be reasonably formal with well-defined agendas, while with smaller companies it may
be less formal. Whatever the process, there must be minutes of these meetings.
1.4.1.2 It should be evidenced that interim meetings are held by responsible management to monitor the
SHQS&S matters regularly versus objectives and set targets. Verify if this is done. Take into account
that in large companies this review may be part of a formal SHQS committee which meets regularly,
while in smaller companies this may be less formal but no less effective.
1.4.1.3 Safety walk abouts are internal periodical safety inspections. (Sr)management should perform a role
model and show involvement. Therefore it is important that they participate in SHE inspections. A
walkabout every trimester is a minimum. The involvement of Sr management should be seen every
year.
1.4.2 Internal Communication
1.4.2.1 There should be a process in place between the management and employees on QHSSE to share
learning and to raise any issues of concern. Ways to achieve this may be through QHSSE meetings
or one to one discussions. Ask for objective documented evidence that feedback is shared and input
from employees is encouraged.
1.4.3.1-3 For an effective control of the Management Systems it is necessary to audit each stage of the
management system. Such audit(s) should be thorough and comprehensive. The assessor should
look for a written audit plan indicating a detailed system. A document detailing what will be audited,
the frequency and who will do it must be available. Look specifically if the areas as referred to in
IMPCAS TCO are sufficiently covered. At least 80% of the chapters must have been subject to an
internal audit before a positive score can be given.
1.5.1 Insurance
1.5.1.1a-f Verify that the company has insurance policies that meet legal and customer requirements to cover
the requirements a - f. Check the validity periods.
2.1.1d Look for regular reviews (minutes of meetings) or risk assessments within defined intervals.
Emphasis on environment is necessary.
2.1.1e Look for regular reviews (minutes of meetings) or risk assessments within defined intervals based on
the listed vulnerable products and logistic modes. Emphasis on security is necessary.
2.1.1f Verify the risk assessment system as well as the company’s internal computer system security, e.g.
on EDI links, order processing and use of customer order details on an Internet site.
2.1.2 Look for documentary evidence of communicated and implemented changes in the various
applicable SHEQ&Sec management system documentation and registrations.
2.1.3 Safe and consistent approach in line with existing guidelines (IMO/ILO/UN ECE/Safe packing of
CTU's)
This section evaluates the ERS capabilities of the company itself (including those organisations to
which it specifically subcontracted) and is independent of the measures and facilities that are
coordinated by the national emergency services or authorities. To achieve a positive score, the
Response Plan and the ERS capabilities of the organization must meet International Chemical
Environment (ICE) level 3 requirements for both onsite and offsite incidents. Level 3 assistance
means active assistance by competent personnel and/or equipment at the scene of the incident.
This section applies to own operations only. The controls over subcontractor activities are covered in
subcontracting. The assessor shall provide adequate comments when "off-site" is not applicable
(e.g. Non Asset based, office only), and score "No" (supported with adequate comments) when
specific items are not fulfilled in one of the systems, for example when they are part of the authority's
scheme and responsibility.
2.2.2.1 The written emergency plan should cover all applicable scenarios and should be regularly updated.
Check if all the described arrangements are in place. Verify if individuals understand their specific
responsibilities in case of an emergency. The emergency response plan should also contain any
customer specific contacts on a 24/7 basis. An emergency may turn into a crisis. Check that this
crisis plan which may be part of the emergency plan.
2.2.2.2a The auditor should check that responsibilities from top management down to the Incident supervisor
are clearly defined, this being to assist with clear lines of demarcation and reporting.
2.2.2.2c The auditor should ask for a register of Incident supervisors and what method is used to obtain 24/7
coverage, from this point questions should be asked of the incident supervisors onsite as to 24/7
coverage and the receipt by them of the schedule for 24/7 coverage.
2.2.2.2d The emergency response plan should detail parties to be informed in the event of an emergency,
both internally and externally.
2.2.2.3 Check that this is procedure is incorporated into the emergency plan. Look also for up to date list of
contact numbers.
2.2.2.4 Fire hoses, fire extinguishers, eye bottles, emergency showers, breathing apparatus, first aid kit
2.2.2.5 Evidence of a practical emergency exercise to test the system for on-site emergencies during the
last 12 months is required.
2.2.2.6 This is a plan to ensure that operations continue in case of business disruptions
2.4. Environment
2.4.1- 2.4.5 Check that the requirements stated in 2.4.1 - 2.4.5 inclusive are adequately addressed. Where
necessary samples should be selected.
2.5.1a - c Check that the requirements stated in 2.5.1a-c inclusive are adequately addressed. Where
necessary samples should be selected
3.2.4 Check the internal system that vehicle movements are controlled within the site.
3.2.5 Verify the company’s internal computer system security, e.g. on EDI links, order processing and use
of customer order details on an Internet site.
3.2.6 Verify adequate manning levels
Note: When the assessed site is part of a shared facility, a comment should be provided
when this requirement cannot be met. In this case the organisation being audited shall be
expected to declare how security threats form neighbouring facilities are catered for.
3.2.7 The procedure may involve badges, keys, etc. Issuance/removal by management and must be
documented i.e. which employees get keys, what level of access is granted to which employees, the
procedure to cancel the key, in the event it is lost, stolen, or if an employee leaves the company.
4.1.2 a - k It is essential that the Quality System is studied in detail, to establish that it covers the items listed.
Evidence of each item to be seen and only marked as “Yes” if present in the Manual (or next layer
documentation) and is being used.
4.5 Contacts
4.5.1 Verify that a contingency exists and look for examples of sickness, leave etc. where replacements
staff/operatives have been used.
Note: Question range 4.6 is only applicable to companies seeking compliance verification with the
American Chemistry Council Responsible Care Management System® Technical
Specification. For all other companies, the entire section can be answered as N/A.
5.1.2a-d For this sample of transactions, look for a risk analysis covering the relevant QHSSE elements.
5.4.1.2 It is of critical importance that any service which is subcontracted to another operator is operated to
equivalent safety and quality standards as that of the main contractor. The auditor should verify that
these imperatives are adequately carried out.
5.4.1.3 The subcontracting policy shall describe the process for selecting subcontractors and should clearly
state that any other transport services will not be subcontracted until the subcontractors' QHSSE
management system have been assessed and judged to be of a acceptable standard to that of the
contracting logistics chain supplier. The agreements with subcontractors should state the conditions
for on-going assessment of the sub-contractors' performance and there should be evidence that the
company carry out these assessments. The agreement should take into account any reasonable
restrictions defined by the customers. Only one level of sub-contracting is allowed unless explicitly
agreed otherwise with the customer (I.E. no sub-sub-contracting).
5.5.2.4 Review a sample of agreements and verify that these include a clause giving the company the right
to carry out on site QHSSE assessments.
5.5.2.5a-b Compliance with the evaluation criteria as described in 5.5.1 should be checked before agreements
are signed and be monitored at least on an annual basis. Check for documented evidence that
performance monitoring has taken place by reviewing the CDI/SQAS assessments of these logistics
service providers or by direct auditing.
5.5.2.6 Check for evidence through meeting reports and follow-up on agreed action programmes. These
meetings should be held on a regular basis, in accordance with the level of business involved.
6.1.3 Ask how, and by whom. Look for records and valid certificates.
6.3.2.2a-e Verify that records confirm calibration has been carried out in accordance with applicable legislation.
6.3.2.3 Verify that records are maintained and are consistent with the calibration equipment being used.
Note: In following questions, the assessor judges the compliance based on reasonableness (80/20
rule), meaning that he reviews the key logistics partner(s) engaged by the company.
This section need only be completed by companies seeking compliance verification with the ACC
Responsible Care Management System® , Technical Specification. For all other companies, the
section may be answered as N/A.
Check contracts with service partners, selected form the approved suppliers' list, for security
8.1.2a-d clauses, requirements, etc., as detailed in 8.1.1a - d inclusive.
Check for documented evidence. As an example an EIR (Equipment Interchange Receipt?) could be
used.
8.2 Interview a selection of operatives. Verify that the both company's and their subcontractors'
operatives comply with their company's procedures which in turn shall comply with ADR/IMDG
8.3.1 Check from recent transactions, whether High Consequence Dangerous Goods are being
transported. If so the container operator's security plan shall meet the requirements of both IMDG
and ADR.
8.4.1 Verify that arrangements are in place and are adequate for tracking and tracing HCDG while in
transit. Arrangements could include GPS tracking, periodical contacts, Internet connection, etc.
8.4.2 Look for sealing procedure and unique numbered seals recorded on transport documentation. Check
that the practices on sealing by interviewing personnel for their understanding of these arrangements
and verify that instructions are being implemented.
8.4.3 A reporting system for seal discrepancies must be in place, including investigation and follow-up.
9.1.2 This question (items a -i) only scores if there is a documented system in place and implemented, for
defining, recording and investigating non conformances, including by whom, how, what and when,
and the process of follow-up and close out of corrective actions.
9.1.3 Check for each work permit or procedure if the requirements are clearly identified. Check if the work
permit system or procedures are implemented as required in 9.1.3a - 9.1.3c
9.1.4 The auditor should look for operating procedures and instructions that cover clean up and disposal of
spillages, as required in 9.1.4a - 9.1.4c inclusive.
9.2.1 Select a sample of transactions for loading between the company and their customers (chemical
companies) and verify that the requirements in 9.2.1a - 9.2.1f inclusive are clearly stated and are
being implemented. Note these checks should include auditing the information in transport
movement orders.
9.2.2 Select a sample of transactions for loading between the company and their customers (chemical
companies) and verify that the requirements in 9.2.2a - 9.2.2d inclusive are clearly stated and are
being implemented. Note these checks should include auditing the information in transport
movement orders.
10.4.1 Check if drivers manual are produced and distributed to all drivers in a language they can
understand. Take a random check by asking 2 or more drivers if the manual is present. Examine
selected instructions to check that details are up-to-date. The score is “No” if significant details are
out of date.
10.4.2a-dd Scores a "Yes" for each listed item for which an instruction exists that covers critical SHEQ&S
aspects. Check that the drivers manual is up-to-date by checking references to updates in
ADR/IMDG and/or other applicable legislation and developments. Verify a sample of driver's
handbooks that the information in 10.4.3a - 10.4.3dd inclusive has been included.
11.1 Records
11.1.1 Pick several deliveries at random. Score a "Yes" for each of the listed items if the requirements in
11.1.1a - 11.1.1h have been adequately covered
Note This section covers the physical inspection, by the assessor, outside on the site of the
assessed company.
An effective system of management will be reflected in the site e.g. its content, layout,
condition and modus operandi. The scope of the site inspection should cover the office
buildings, maintenance workshop, parking, fuel station. Any bulk storage of products from
customers.
12.2.2 The condition of the fences, gates, roadways, parking areas and buildings gives an indication on how
seriously the site management is interested in quality and safe operation, and not only in commercial
affairs. This is also important for the image of the company. Look for example if there are potholes
or flakes of water on the parking areas.
12.2.3 Walkways prevent uncontrolled traffic flow on the site and protect walking people by organised
routes on the site. They should be marked out as a permanent feature.
12.2.4 The access to the site should be such that no safety hazard is caused to other traffic (good
visibility/no narrow streets). The traffic flow on the site should be logical, transparent and free
flowing.
12.2.5 If parking of loaded trailers on the site property is allowed, it should be done properly using support
pads to prevent landing gear pushing through any weakness in the road surface and resulting in
trailer tip-over.
Internal transfer of packaged goods
Check that SDS are available, packing notes correct, class labels identifying goods etc. Ensure that
a segregation table is displayed. Is there adequate segregation from an office building from a
hazardous goods area where/flammable goods are stored. There should be at least two accesses,
as far apart as physically possible.
verify from records that training has been given to employees.
ensure PPE is in place and in good condition.
An area for hazardous goods storage which provides containment ,i.e. an impermeable floor and
drainage to a collector.
Containers dedicated for debris, waste should be stored in special, dedicated containers, and these
containers should be properly stored themselves. For example containers should be hazards waste
should be stored sheltered from rain and direct sunlight. The auditor should look at requirements for
storage in the operating permit and check that these requirements are being met.