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CDI

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

© 2012 Chemical Distribution Institute

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.

NOTICE OF TERMS AND USE

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
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IMPCAS
Container Freight Station Questionnaire
List of Abbreviations

Index

Introduction

List Of Abbreviations

A. General Information

A.1 Company Safety History

B. Audit Summary

Sect 1. Container Freight Station Management


1.1 Management Responsibility
1.2 Personnel
1.3 QHSSE Performance Analysis
1.4 Management Review
1.5 Insurance
Sect 2 Safety, Health, Security and Environment
2.1 Risk Management
2.2 Safety
2.3 Occupational Health & Safety
2.4 Environment
2.5 Spill Prevention and Control

Sect 3 Security
3.1 Security Standards and Procedures
3.2 Site Security
3.3 Security Training

Sect 4 QMS and Responsible Care®


4.1 Quality System
4.2 Purchasing of Critical Materials and Services
4.3 Control of purchased materials and services
4.4 Suppliers of Critical Goods and Services
4.5 Contacts
4.6 Responsible Care®

Sect 5 Supply Chain Management and Subcontracting


5.1 Choice of Logistic Solutions
5.2 Supply Chain Management
5.3 Supply Chain Integrity/Supply Chain Management
5.4 Subcontracting Services
5.5 Performance criteria

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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

Sect 7 Responsible Care Management System


7.1 Responsible Care Management System

Sect 8 Intermodal Security


8.1 Security Plan
8.2 Security during intermodal transport moves
8.3 Legal requirements for High Consequence Dangerous Goods (HCDG)
8.4 Best practices for intermodal transport security of HCDG

Sect 9 Site Operating Procedures and Customer Interface


9.1 Operating Instructions
9.2 Customer Interface

Sect 10 Order Process and Port Agency Operations


10.1 Order Planning
10.2 Order instructions for multimodal shipments
10.3 Operator Handling
10.4 Driver instructions on entering/departing the site (Driver Manual issued by Intermodal
operator)
Sect 11 Administration
11.1 Records

Sect 12 Site Inspection


12.1 Office and buildings
12.2 Depot and Parking
12.3 Internal handling transfer of packaged goods

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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.

Structure of the Questionnaire.

Questions are to be answered: ''Yes'', ''No'' or ''N/A''

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

It is a requirement that all questions (statements) in the Questionnaire are answered.


Sampling of questions within the report is not permitted. However, sampling within a particular
question is permitted. For example, when assessing the question on the operating
instructions, the Auditor is not expected to sight every operating instruction on site but only a
sufficient number to make a broad judgment that they are displayed or readily available.

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

Each question must have one of its check boxes marked.

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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Container Freight Station Questionnaire
Introduction

Processing the Report

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.

Except in exceptional circumstances (or when instructed by IMPCAS), copies of the


Questionnaire should not be faxed, or transmitted by any other means, to any person or
business who is not the MPC Operator. Questionnaire data is privy to the Auditor (which
includes persons employed by the Auditor or under the direct control of the Auditor) and the
MPC Operator. Persons who do not have approved access to the Questionnaire data on the
electronic database, are not permitted to sight the Questionnaire data in hand-written or typed
hard copy.

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.

A certificate of attestation will be issued from the IMPCAS database.

CFS Intro
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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.

ACC American Chemistry Council


ACEP Accepted Continuous Examination Program
ADR European Agreement concerning the international carriage of dangerous goods by road

BBS Behaviour Based Safety

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

EDI Electronic Data


EIR Equipment Interchange Receipt

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

LSP Logistic Service Provider

M Mandatory
MPC Marine Pack Cargo

N/A Not applicable or not addressed

PES Periodic Examination Scheme


PPE Personal Protective Equipment

QHSSE Quality, Health, Safety Security & Environment,


QS Quality System

RC Responsible Care
RID Regulations Concerning the international carriage of dangerous goods by rail.

SDS Safety Data Sheets


SMS Safety Management System
SQAS Safety and Quality Assessment System
UN United Nations

CFS Intro
Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 10
Section A Container Freight Station GENERAL INFORMATION

A.1 General Information

Date of Audit :-_______________________________

Audited By :- __________________________________________________(Name)

Company information :-

Name Of Audited Company :-_______________________________________________

Address:-

Tel:-_____________________________ Fax:-____________________________

Contact Person(s) :-

Name :-

E-Mail :-

Name :-

E-Mail :-

Date Of Last CDI-impcas Audit Report :- (if applicable)

CDI-impcas Audit Report Number :-

ISO Certificate issued by :- (if applicable)

ISO Certificate Valid Until:-

Branch Offices:-
Address:-

Address:-

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Section A Container Freight Station GENERAL INFORMATION

A.2 General Information

Company Safety History


Year to Date Previous Year

1 Number of mpc loaded shipped?

2 Percent loaded dangerous goods shipments?

3 Number of reported chemical incidents.

4 Number attributed to your company ?

5 Number attributed to your contractor?

6 Number attributed to shipping contractor?

7 Number caused by third party ?

CFS Gen Info


Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 12
Section A Container Freight Station Guidance Notes

A.1 General Information

Date of Audit The date when the audit completed.

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"

CFS G-N Gen Info


Rev 2: IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 13
Section B Container Freight Station Audit Summary

Ref Closing Meeting, Observations and Remarks Yes No N/A

Record of Negative Answers form provided to the Manager

Summary of Observations and Remarks provided to the Manager

Observations and remarks discussed with the Manager

Summary of Observation and Remarks


Included are:-

1 Observations to negative answers requiring explanation.

2 Remarks to any answer or section deserving further


explanation

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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
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Container Freight Station Management Summary Guidance Notes
Section B Guidance Notes
Closing Meeting, Observations and Remarks

Record of Negative Answers

The record of Negative Answers form shall be completed by the Auditor


and given to the Manager on completion of the audit

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.

Summary of Observations and Remarks

The Summary of Observations and remarks should be completed by the


Auditor and if time permits a copy given to the Manager on completion of
the Audit, or by other means as soon as practically possible.

For those Negative Answers requiring an explanation, the explanation


shall take the form of an observation

The Auditor may make objective remarks to any answer or section


deserving further expansion.

Observations and Remarks should be numbered consecutively, but need


not be sorted. It is a function of the database to sort and present the
Observations and Remarks.

Any comments the Manager wishes to make on the content of the


questionnaire should be noted on the list of Observations and Remarks.
Any comments must be accompanied by the Manager's signature.

CFS G-N Audit Summary


Rev IMPCAS 10-2012 (C) 2012 Chemical Distribution Institute 1
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.1 Management Responsibility Y N N/A cat

1.1.1 Company Policies


1.1.1.1 Does the company have a current written policy reflecting management's active
commitment to :
1.1.1.1a c - Safety & Health ? M RC
1.1.1.1b c - Environment ? M RC
1.1.1.1c c - Quality ? M RC
1.1.1.1d c - Security ? M RC
1.1.1.1e c - Meeting customers requirements ? M RC
1.1.1.1f c - Training development ? I RC
1.1.1.1g c - Non conformance reporting ? I RC

1.1.1.2 Does the company policy include a programmes with regard to :


1.1.1.2a c - Behaviour Based Safety (BBS) ? or similar safety based programme ? I
1.1.1.2b c - Drugs and Alcohol ? M
1.1.1.2c c - Security (protecting people and property from loss by intentional destruction or M
theft) ?
1.1.1.2d c - Employee involvement in all QHSSE matters ? I RC

1.1.2 Roles & Responsibilities


1.1.2.1 c Is there an organisation chart defining each individual's role within the organisation, I RC
including the responsibilities for QHSSE ?
1.1.2.2 c Are senior managers sufficiently visible and effective in carrying forward the I RC
SHEQ&S message?
1.1.2.3 c Does the leadership interact and constructively encourage employees to be actively I RC
engaged in SHEQ&S performance improvement?
1.1.2.4 Is a person formally designated or a source defined to keep the company abreast of RC
all relevant legislation and legislative developments in the area of:
1.1.2.4a c - Safety & Health ? I RC
1.1.2.4b c - Environment ? I RC
1.1.2.4c c - Quality ? I RC
1.1.2.4d c - Security ? I RC

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 ?

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Section 1 Container Freight Station Management
IMPCAS Core Questions
1.2 Personnel Y N N/A cat

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

1.2.2.8 c Is the effectiveness of the training checked for each employee ? I RC

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Section 1 Container Freight Station Management
IMPCAS Core Questions
1.3 QHSSE Performance Analysis Y N N/A cat

1.3.1 Non-conformances Reporting, Investigation, Analysis and Corrective Action


1.3.1.1 Is there a documented system in place for identifying, recording and investigating
non-conformances regarding :
1.3.1.1a c - accidents ? I RC
1.3.1.1b c - incidents ? I RC
1.3.1.1c c - near-misses ? I RC
1.3.1.1d c - potential health issues ? I RC
1.3.1.1e c - breaches of security and threats? I RC
1.3.1.1f c - regulatory compliance? M RC

1.3.1.1g c - unsafe behaviour & unsafe conditions ? I RC


1.3.1.1h c - product contamination ? I RC
1.3.1.1i c - product discrepancies and short shipments ? I RC
1.3.1.1j c - quality of services ? 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

1.3.1.1n - Lashing and securing ?(also known as Block and Brace) I RC

1.3.1.1o - placarding/labelling/marking (IMDG Code Chapter 5) I RC

1.3.1.1p - Packing and unpacking container's I RC

1.3.1.1q - short shipments ? I RC


1.3.1.2 c Is the DGA involved after an incident where dangerous goods were involved? I RC
1.3.1.3 c Are immediate actions taken to avoid problems pending further investigation ? I RC
1.3.1.4 c Is there a procedure requiring the written notification within 24 hours of all non I RC
conformances to the customer involving their products ?
1.3.1.5 Is a detailed report prepared on non-compliances for the responsible management
and the customer, containing :
1.3.1.5a c - an investigation to establish the immediate cause of the non-conformance ? I RC
1.3.1.5b c - the identification of root causes ? I RC
1.3.1.5c c - recommendations for corrective actions to prevent recurrence ? I RC

1.3.2 QHSSE Trend Analysis and Improvement Objectives


1.3.2.1 Is there a process in place for the analysis of data to identify trends for :
1.3.2.1a c - Safety & Health ? I RC
1.3.2.1b c - Quality ? I RC
1.3.2.1c c - Security ? 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 ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 20
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.4 Management Review Y N N/A cat

1.4.1 Management Review


1.4.1.1 c Do formal annual management meetings review the following elements of the
QHSSE management systems:
1.4.1.1a c - Safety & Health ? I RC
1.4.1.1b c - Environment ? I RC
1.4.1.1c c - Quality ? I RC
1.4.1.1d c - Security ? I RC

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

1.4.3 Internal Audit


1.4.3.1 c Is there a documented plan for internal auditing of all areas referred to in this I RC
IMPCAS Questionnaire?
1.4.3.2 c Are internal audits carried out as per plan with competent auditors ? I RC
1.4.3.3 c For shortcomings identified in the audits, are action plans developed and are I RC
corrective actions taken ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 21
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.5 Insurance Y N N/A cat

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 :

1.5.1.1a c - comprehensive public liability ? M


1.5.1.1b c - motor vehicle liability ? M
1.5.1.1c c - environmental liability ? M
1.5.1.1d c - goods in transit ? M
1.5.1.1e c - equipment (container / tank container liability ? M
1.5.1.1f c - back to back agreements with suppliers used for intermodal movements ? M

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 22
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.1 Risk Management Y N N/A cat

2.1 Risk Management


2.1.1 Is there a process to assess and document the Safety, Health, Environmental and
Security risks , related to all activities of the company, considering following aspects:

2.1.1a c - start-up of new operations/activities (e.g. new products, new routes) ? I RC

2.1.1b c - change of operations/activities (Management of Change) ? I RC


2.1.1c c - periodic review of risks on current activities? I RC
2.1.1d c - does management of change and risk evaluation include environmental I RC
2.1.1e c - does management of change and risk evaluation include security aspects? I RC
2.1.1f c - has a risk assessment been conducted regarding computer information on I C-TPAT RC
customers, products and operations and are measures taken to mitigate identified
risks?
2.1.2 c Is there a procedure present that legislative changes are communicated and I RC
implemented in the company ?
2.1.3 c Are measures taken to control/mitigate all identified potential risks ? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 23
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.2 Safety Y N N/A cat

2.2.1 Personal Protective Equipment (PPE)


2.2.1.1 c Is there a written procedure defining what PPE has to be used under what M RC
circumstances ?
2.2.1.2 c Is the PPE regularly checked (before use and at set intervals) and replaced when M RC
required ?
2.2.1.3 c Is there specialised equipment with instructions/training for use for critical chemicals M RC
?
2.2.1.4 c Is there evidence that equipment is used ? I RC

2.2.1.5 Are the following items although not restricted to issued to employees:-
2.2.1.5a - protective gloves ? I RC

2.2.1.5b - high visibility overalls/outer wear I RC

2.2.1.5c - safety boots/shoes I RC


2.2.1.5d - dust masks I RC
2.2.1.5e - eye protection I RC

2.2.1.5f - hard hat I RC

2.2.2 On Site Emergency & Security Preparedness and Response


2.2.2.1 Is there a written plan for dealing with on-site emergencies and potential crises? I RC

2.2.2.2 Does this written plan contain the following information :


2.2.2.2a - individual responsibilities ? I RC

2.2.2.2b - training requirements for of the responsible personnel ? I RC


2.2.2.2c - arrangements for 24/7 hours coverage by trained responders ? I RC
2.2.2.2d - a list of the different parties to be informed with their contact details (customers, I C-TPAT RC
authorities) ?
2.2.2.3 Is there a procedure for handling the information towards the neighbourhood, the I RC
press and other interested parties of serious accidents/incidents that happened on
2.2.2.4 site?
Is the emergency equipment maintained, tested or checked on a regular basis? I RC
2.2.2.5 Has there been a comprehensive test of the emergency plan for on-site I RC
emergencies during the past 12 months ?
2.2.2.6 Is there a documented business continuity plan and does this plan contain the I RC
customer contacts to be informed ?
2.2.2.7 In the event of an emergency can safety data sheets be easily transmitted to I RC
responders ?
2.2.2.8 Does the emergency equipment include:
2.2.2.8a - oversized drums/UN approved salvage drums ? I RC
2.2.2.8b - eyewash station and /or bottles/ emergency shower ? I RC
2.2.2.8c - absorbents/clean up materials ? I RC
2.2.2.8d - personal protective equipment for ALL products to be responded to ? 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)?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 24
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.3 Occupational Health & Safety Y N N/A cat

2.3 Occupational Health & Safety


2.3.1 c Does the operating site have access to the DGA for advice for all products M
2.3.2 c transported and/or handled
Are current Material ?
Safety Data Sheets available from the manufacturers for all M RC
products transported and/or handled ?
2.3.3 c Has a review been carried out by a competent person on any new chemical to be M RC
transported before accepting the order (e.g. DGA) ?
2.3.4 c Are prevention measures being used to control all identified potential health hazards I RC
2.3.5 c Are drivers/depot operators subject to a medical examination before employment ? I RC
2.3.6 c Are all drivers/depot operators given a periodic medical examination dependent on I RC
the risks to which they are exposed ?
2.3.7 c Are there systems in place to provide first aid capability ? I RC
2.3.8 c Is there a written reporting procedure for accidents and potential health hazards ? I RC
2.3.9 c Is a first aid training programme defined and followed ? I RC

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?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 25
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.4 Environment Y N N/A cat

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

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 26
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.5 Spill Prevention and Control Y N N/A cat

2.5 Spill Prevention and Control


2.5.1 Is spill prevention an integral part of:
2.5.1a c - equipment selection ? I RC
2.5.1b c - operators/drivers training programmes ? I RC
2.5.1c c - maintenance programmes ? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 27
Section 3 Security
IMPCAS Core Questions
3 Security Y N N/A cat

3.1 Security standards and procedures

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?

3.3 Security Training


3.3.1 Do all involved personnel attend security awareness training which covers :
3.3.1a c - recognition of security risks ? I C-TPAT
3.3.1b c - methods to address and reduce security risk ? I C-TPAT
3.3.1c c - actions to be taken in the event of a breach of security ? I C-TPAT
3.3.1d c - recognition of internal conspiracies ? I C-TPAT
3.3.1e c - maintaining cargo integrity ? I C-TPAT
3.3.1f c - determining and addressing unauthorised access ? I C-TPAT

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 28
Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care® Y N N/A cat

4.1 Quality System


4.1.1 c Does the quality manual clearly describe a system of quality management as per I RC
ISO 9001:2008 or equivalent?
4.1.2 c Does the scope of the quality system cover the following elements :
4.1.2a c - company policy on quality assurance? I RC
4.1.2b c - the organisation structure and lines of communication ? I RC
4.1.2c c - clearly defined responsibility, authority and interfaces ? I RC
4.1.2d c - non-conformances Reporting, Investigation, Analysis and Corrective Action ? I RC
4.1.2e c - customer contract review ? I RC
4.1.2f c - the method whereby the processing of customer orders is controlled ? I RC
4.1.2g c - the method whereby handling of non-conforming product/service and corrective I RC

4.1.2h c action are controlled?


- the method whereby purchasing activities are controlled ? I RC
4.1.2i c - the method whereby the maintenance of equipment is controlled ? I RC
4.1.2j c - establishing training program ? I RC
4.1.2k c - issue, revision and distribution of controlled documents ? I RC

4.2 Purchasing of Critical Materials and Services


4.2.1 c Are the specifications for critical services and products communicated to suppliers in I RC
writing ?
4.3 Control of purchased materials and services
4.3.1 c Are suppliers of critical goods and services reviewed and selected on the basis of a I RC
4.3.2 c Are goods inspected and services evaluated for conformance to agreed I
specification ?
4.4 Suppliers of critical goods and services
4.4.1 c Are non conformances resulting from suppliers of critical goods and services dealt I RC
with as per Section 1.3 Non-conformances Reporting, Investigation, Analysis and
4.5 Corrective
Contacts Action ?
4.5.1 c Is there a contingency plan to maintain the planning capability in the event of I
sickness, holidays, unforeseen circumstances, etc. ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 29
Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care® Y N N/A cat

4.6 Responsible Care®


4.6.1 c Has the company a policy statement which clearly reflects a commitment to the I RC
Responsible Care Guiding Principles?
4.6.2 c Do the company policy statements drive setting Responsible Care/EHSS objectives I RC
4.6.3 c Do the company policy statements commit to comply with legal and Responsible I RC
Care related requirements?
4.6.4 c Does the management system allow for verification that resources are sufficient and I RC
appropriately allocated to meet Responsible Care goals, objectives and targets?
4.6.5 c Does the organization assist in the development of responsible standards that I RC
safeguard the community, workplace and environment?
4.6.6 c Is there a system to assure that the organization is meeting it's Responsible Care I RC
reporting obligations according to established timetables?
4.6.7 c Does the policy statement encourage employees' involvement in and commitment to I RC
the company's Safety, Health, Environment and Quality objectives?
4.6.8 c Is there a well publicised award/reward scheme to encourage improvements in I RC
Safety, Health, Environment and Quality Performance?
4.6.9 c Are the company policy statements communicated to stakeholders and members of I RC
4.6.10 c Does the company have Bulletin Boards (or other means of open communication i.e. I RC
websites) which promote Safety, Health, Environment and Quality matters ?
4.6.10a c - Are bulletins issued at regular intervals ? I RC
4.6.11 c Is there a system to assess stakeholder perspectives? I RC
4.6.12 c Do the established Responsible Care/EHSS objectives and targets take into I RC
consideration stakeholder perspectives?
4.6.13 c Is the effectiveness of internal and external communication plans measured? I RC
4.6.14 c Does the company Emergency Plan clearly reference the different types of incident I RC
that the company may suffer?
4.6.15 Do the Emergency Plan references to different types of incidents include:
4.6.15a c - Product incidents? I RC
4.6.15b c - Waste incidents? I RC
4.6.15c c - Transport incidents? I RC

4.6.15d - Handling incidents? I RC

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?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 30
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.1 Choice of Logistic Solutions Y N N/A cat

5.1 Choice of Logistics Solutions


5.1.1 c Is there a documented process for defining and choosing the logistics solution and I C-TPAT RC
selecting the service partners for each business assigned to the company including
a risk assessment covering SHEQ&S elements?
5.1.2 Does the logistics solution cover the following aspects ?
5.1.2a c - Safety & Health ? I RC
5.1.2b c - Environment ? I RC
5.1.2c c - Quality ? I RC
5.1.2d c - Security ? I C-TPAT RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 31
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.2 Supply Chain Management Y N N/A cat

5.2 Supply Chain Management


5.2.1 Do annual QHSSE targets communicated to all involved service providers in the
supply chain include:
5.2.1a c - Safety & Health ? I RC
5.2.1b c - Environment ? I RC
5.2.1c c - Quality ? I RC
5.2.1d c - Security ? I C-TPAT RC

5.2.2 Does the company follow-up the service providers' actions to ensure achievement of I C-TPAT RC
the targets ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 32
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.3 Supply Chain Integrity Y N N/A cat

5.3 Supply Chain Integrity


5.3.1 Has the company a documented process to control its services from loading point to I C-TPAT
delivery at the final consignee ?
5.3.2 Are all customer instructions and requirements followed through over the complete I
supply chain, when multiple service partners are involved ?
5.3.3 Does the company have a formal process in place enabling on-time delivery I C-TPAT
reporting and follow-up at all stages of the supply chain (including identity of person
and reason causing or requesting changes) ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 33
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.4 Subcontracting Services Y N N/A cat

5.4.1 Subcontracting policy


5.4.1.1 Does the company have a written policy for subcontracting transport and transport I C-TPAT RC
related services (including selection process, performance assessment and
5.4.1.2 monitoring) ?
Are the requirements and restrictions of the customer chemical companies reflected I C-TPAT RC
in the subcontracting policy ?
5.4.1.3 Does the company policy reflect the restrictions regarding spot subcontracting for I C-TPAT
chemical haulage ?
5.4.2 Approved subcontractors
5.4.2.1 Does the company maintain an up-to-date list of fully approved subcontractors ? I C-TPAT RC
5.4.2.2 Are the subcontracting requirements (as outlined in the performance criteria of I C-TPAT RC
5.3.1.) defined in a written agreement, monitored and documented for all approved
subcontractors ?
5.4.2.3 Are the drivers/operators of approved subcontractors taking part in the company's I RC
safety and quality trainings and programs ?
5.4.3 Unplanned spot services by subcontractors
5.4.3.1 When the company has to deploy unplanned resources in the supply chain, are the I C-TPAT
minimal service requirements defined and requested for these service partners ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 34
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.5 Performance monitoring of logistics partners Y N N/A cat

5.5.1 Performance Criteria


5.5.1.1 Does the written service agreement with each subcontractor contain the
requirements and standards related to following criteria :
5.5.1.1a - compliance with all relevant national and international regulations and laws ? M C-TPAT RC
5.5.1.1b - operating licenses consistent with the activities and operations ? M RC
5.5.1.1c - drivers/operators holding valid national licenses/certificates ? M RC
5.5.1.1d - working/driving hours compliance and keeping records ? M RC
5.5.1.1e - drugs and alcohol policy ? I RC
5.5.1.1f - vehicle parking ? I C-TPAT RC
5.5.1.1g - carry forward transport and customs documents to all service partners in the I C-TPAT RC
chain, including EIR (Equipment Interchange Receipt) if required ?
5.5.1.1h - use of emergency number / emergency response capabilities ? I RC
5.5.1.1i - appointment and fulfilment of the duties of the DGA ? M RC
5.5.1.1j - vehicle / equipment maintenance, inspection and testing? M RC
5.5.1.1k - observation of instructions/practices at loading and unloading sites (including I RC
working on height, safe entry procedure to enclosed spaces, safe sampling
practices, cleanliness of equipment) ?
5.5.1.1l - adequate driver selection and training, driver manual content, driver pre-start I RC
and post-loading checks, defensive driver training, BBS, wearing seat-belts,
parking of vehicles, weight limits in different countries) ?
5.5.1.1m - secondary subcontracting of haulage ? I RC
5.5.1.1n - comprehensive insurance coverage ? M RC
5.5.1.1o - handling of and reporting non-conformances ? I RC
5.5.1.1p - accident/incident reporting (incl. near-miss reporting) ? I RC
5.5.1.1q - confidentiality of operational and commercial data ? I RC
5.5.1.1r - security provisions as required by applicable legislation ? M C-TPAT RC

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 ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 35
Section 6 Equipment
IMPCAS Specific Questions
6.1 Equipment Specification Y N N/A cat

6.1 Equipment Specification


6.1.1 Is there a procedure covering all aspects and responsibilities for the purchase/lease I
of equipment ?

6.1.2 Does the written specification include :


6.1.2a - Roll over protection system (roll cage) for handling equipment (e.g. fork lift I RC
6.1.2b - Falling object protection system (cab top shielding) for handling equipment ? I RC
6.1.2c - ease of external cleaning ? I RC
6.1.2d - seatbelts ? I RC
- fire extinguishers on plant and equipment ? I RC
6.1.2e
6.1.2f - compliance with applicable legislation on noise emission ? I RC
6.1.2g - compliance with applicable legislation on exhaust emission ? I RC
6.1.2h - audible alarm when fork lift is reversing? I RC

6.1.2i - other safety aspects ? I RC

6.1.3 Is handling/lifting equipment checked against specification before use ? I

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 36
Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance, and Calibration Y N N/A cat

6.2.1 Equipment Inspection and Maintenance (Service)


6.2.1.1 Is there a documented programme for preventive inspection and maintenance,
covering the following equipment :
6.2.1.1a - rolling equipment ? I RC
6.2.1.1b - lifting frames barrel clamps and other cargo handling devices fitted to fork lift I RC
6.2.1.1c - ropes, wires and chains ? I RC
6.2.1.1d - bottles, screws, spanners ? I RC
6.2.1.1e - powered lifting equipment ? I RC
6.2.1.1f - hooks, shackles I RC
6.2.1.1g - bridge fittings ? I RC

6.2.1.2 Is there a documented procedure:


6.2.1.2a - to monitor the inspection and maintenance process ? I RC

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

6.2.2.1b - periodically tested and certified according to legislation ? M RC


6.2.2.1c - fitted with an overload safety system ? M RC
6.2.2.1d - fitted with a sway protection system ? M RC

6.2.3 Rolling equipment


6.2.3.1 Is the rolling stock which is in use (e.g. forklifts, mafi's, trailers, etc.)
6.2.3.1a - SWL (Safe Working Load) certified ? M RC

6.2.3.1b - fitted with flame arrestors, if running on diesel ? M RC

6.2.3.1c - flame proof, if running on electricity ? M RC

6.2.3.1d - fitted with adequate locking devices ? M C-TPAT RC

6.2.3.1e - periodically tested and certified according to legislation ? M RC

6.2.3.2 Is there a documented procedure:


6.2.3.2a - to monitor the inspection and maintenance process ? I 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 ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 37
Section 6 Equipment
IMPCAS Specific Questions
6.3 Equipment Inspection, Maintenance, and Calibration Y N N/A cat

6.3.1 Statutory Examination and Testing


6.3.1.1 Is there a documented procedure for the examination and testing of Containers, in I
accordance with the International Convention for Safe Containers?
6.3.1.2 Do records of test certificates indicate that containers are subjected to the required I
periodic examination and testing ?
6.3.1.3 Do records of examination clearly indicate the following inspections have been
6.3.1.3a completed
- Internalas required ?by International Convention for Safe Containers:
inspection I
6.3.1.3b - External inspection (as far as can be reasonably observed) ? I
6.3.1.3c - Examination of frame where applicable ? I
6.3.1.3d - Examination of markings ? I
6.3.1.3e - Sighting and fixing of the Safety Approval Plate ? I
6.3.2 Identification and Calibration of Measuring & Test Equipment
6.3.2.1 Are calibration procedures in place, incl. identification of all measuring equipment ? I
6.3.2.2 Is calibration carried out in accordance with legislation for the following critical
6.3.2.2a equipment
- oxygen :meters ? M
6.3.2.2b - flammable gas detectors ? M
6.3.2.2c - instruments for measuring concentrations of toxic gases and vapours, M
particularly for detecting harmful levels of fumigant gas inside containers.?
6.3.2.2d - weighbridges? I
6.3.2.2e - tank pressure gauges where applicable ? M
6.3.2.3 Are calibration records maintained ? M

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 38
Section 6 Equipment
IMPCAS Specific Questions
6.4 Equipment of Partners Y N N/A cat

6.4 Equipment of Partners


6.4.1 Does the company have evidence that the purchase or lease of each vehicle and M
associated equipment used by selected subcontractors is in line with the statutory
requirements and industry standards ?

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 ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 39
Section 7 Container Freight Station
IMPCAS Specific Questions
7.0 Responsible Care Management System Y N n/a cat

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 Is there a system to share appropriate risk information with:


7.10.1 carriers? 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

7.10.6 waste disposal contractors? I RC

7.10.7 other commercial partners? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 40
Section 7 Container Freight Station
IMPCAS Specific Questions
7.0 Responsible Care Management System Y N n/a cat

7.11 Is there a system to assess stakeholder perspectives? 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?

7.20 Is information provided concerning EHSS risks to the public? I RC

7.21 Are protective measures pursued concerning EHSS risks to the public? I RC

7.22 Is information provided concerning EHSS risks to other stakeholders? 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

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 41
Section 7 Container Freight Station
IMPCAS Specific Questions
7.0 Responsible Care Management System Y N n/a cat

7.25 Do plans and procedures in place for potential emergencies and incidents consider I RC
normal and abnormal operating conditions?

7.26 Are emergency plans periodically reviewed? I RC

7.27 Do emergency plans include appropriate considerations for communications and I RC


community recovery needs?
7.28 Has consideration been made for the integration of facility emergency response I RC
plans with community emergency response plans?

7.29 Is there a system to address emergency response for off-site or transportation I RC


incidents?
7.30 Does the organization support education and research on the potential EHS effects I RC
of it's product and processes?
7.31 Does the organization assist in the development of responsible laws, regulations I RC
and standards that safeguard the community, workplace and environment?

7.32 Do key personnel have sufficient training and resources for implementation? I RC

7.33 Is the effectiveness of internal and external communication plans measured? 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?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 42
Section 7 Container Freight Station
IMPCAS Specific Questions
7.0 Responsible Care Management System Y N n/a cat

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

7.45 Does a system exist to assess risk for:


7.45.1 new processes? I RC

7.45.2 existing processes? I RC


7.45.3 changes to existing processes? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 43
Section 8 Intermodal Security
IMPCAS Specific Questions
8 Intermodal Security Y N N/A cat

8.1 Security Plan


8.1.1 Has the company developed security provisions regarding its transport distribution M C-TPAT
information ?

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 :

8.1.2a - hauliers ? M C-TPAT


8.1.2b - depots ? M C-TPAT
8.1.2c - cleaning stations ? M C-TPAT
8.1.2d - at the interface with intermodal transport ? M C-TPAT

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 ?

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 44
Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.1 Operating Instructions Y N N/A cat

9.1 Operating Instructions


9.1.1 Does the site have all the required operating licenses (If required) in line with the M RC
activities carried out at the site ?
9.1.2 Is there a documented system in place for recording and investigating non-
conformances regarding :

9.1.2a - product contamination ? I C-TPAT RC


9.1.2b - product discrepancies ? I RC
9.1.2c - transport documentation ? I C-TPAT RC
9.1.2d - transport legislation infringements ? I RC
9.1.2e - placarding/labelling/marking ? I RC
9.1.2f - use of EIR (Equipment Interchange Receipt) / damage occurrence ? I RC
9.1.2g - delay in departure of shipping/rail ? I RC
9.1.2h - short shipments ? I C-TPAT RC
9.1.2i - delays to schedule, transfer time and on-time delivery performance ? I C-TPAT RC

9.1.2j - weight discrepancies between declared and actual? I C-TPAT RC

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 :

9.1.3a - entry into confined spaces ? M RC


9.1.3b - breaking of containment (Drums) ? I C-TPAT RC
9.1.3c - hot work ? M RC
9.1.4 Are there also comprehensive procedures / instructions at the facility for following
9.1.4a - clean up and disposal of chemical spillages ? M RC
9.1.4b - parking segregation for vehicles/tanks/containers carrying different classes of M C-TPAT

9.1.4c -hazardous product ?


safe loading/unloading practices ? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 45
Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.2 Customer Interface Y N N/A cat

9.2 Customer Interface


9.2.1 Has the responsibility for the loading/packing of cargo/goods been defined between
the customer and the CFS operator regarding :
9.2.1a - site access requirements at the loading/packing site ? I RC
9.2.1b - party at the loading/packing site to report to for loading ? I RC
9.2.1c - weight to be loaded ? I RC
9.2.1d - placarding, labelling and marking of the container ? M RC
9.2.1e - authorisation to start loading/packing ? I RC
9.2.1f - documents accompanying the loading process (before/during/after) ? I RC

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

9.2.3 Are meetings held with selected customers to :


9.2.3a - review the QHSSE performance ? I RC
9.2.3b - agree on QHSSE targets and improvement programmes ? I RC

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 46
Section Order Process and Operations
10
IMPCAS Specific Questions
10 Order Process and Operations Y N N/A cat

10.1 Order Planning


10.1.1 Is there a written procedure for order processing and equipment scheduling ? I
10.1.2 Does the planning section communicate all relevant information and instructions to
the contractor/subcontractor, including but not limited to :
10.1.2a - full proper shipping name and UN Number of the product ? I RC
10.1.2b - hazardous nature of the material ? I RC
10.1.2c - consignor/consignee details ? I RC
10.1.2d - time and collection/delivery of product ? I RC
10.1.2e - container capacity / suitability ? I RC
10.1.2f - weight to be loaded ? I RC
10.1.2g - maintenance of product temperature ? I RC
10.1.2h - product compatibility ? I RC
10.1.2i - Competent Authority Approval ? (If applicable) I RC

10.1.2j - Multimodal Dangerous Goods Form? I


10.1.2k - Container Packing Certificate ? I
10.1.2l - Weathering Certificate ? (If applicable) I
10.1.2m - Additional Documentation as required by applicable regulations ? I
10.1.3 Are there procedures in place to ensure that maximum allowable weights are not M
exceeded ?
Order instructions for multimodal shipments
10.2.1 For multimodal shipments, does the order handling instructions to the involved C-TPAT
service partners cover and ensure the following elements :
10.2.1.a - receiving and forwarding shipping instructions ? I C-TPAT
10.2.1b - receiving shipping and/or storage instructions ? I C-TPAT
10.2.1c - issuing customs documentation ? I C-TPAT
10.2.1d - obtaining the Bill of Lading ? I C-TPAT
10.2.1e - preparation of a hazardous cargo booking list (HBL) ? I C-TPAT
10.2.1f - collection of Dangerous Goods Declaration (DGD) ? I C-TPAT
10.2.1g - issuing the relevant shipping documents such as DGD to the shipping agent ? I C-TPAT
10.2.1h - producing and issuing the Bill of Lading, when authorized ? I C-TPAT
10.2.1i - providing all applicable information to the forwarding agent in order to produce I C-TPAT
the Bill of Lading (when company is not authorized to produce the BOL itself) ?
10.2.1j - advising the shipping agent about cargo with special requirements (such as deck I C-TPAT
stowage, heating/cooling requirements, etc.) ?
10.2.1k - is arrival / departure time recorded for individual transit legs ? I C-TPAT
10.2.1l - is tracking and tracing available during the movement of the container ? I C-TPAT
10.2.2 Are there adequate arrangements in place ensuring those that are packing a M RC
container or vehicle do so in compliance with IMDG code chapter 5.4.2.1 of the
IMDG Code
10.2.3 Do written operating instructions require operators:
10.2.3a - to check the condition of individual packages for damage, leaks, staining etc. ? M RC
10.2.3b - to confirm the nature of hazards from the package labels ? M RC
10.2.3c - to visually check the condition of the container before loading? M RC
10.2.3d - to check that the safety approval plate of any freight container is valid? M RC
10.2.3e - to remove irrelevant placards and markings from the outside the container ? M RC
10.2.3f - to follow a loading plan drawn up by a responsible person when packing M RC
10.2.3g - to ensure that packages are properly secured and effectively braced inside M RC
10.2.3h - to ensure that packages are properly segregated inside the container? M RC
10.2.3i - to securely close and seal the container when loading is complete ? M RC
10.2.3j - to ensure that the container packing certificate/vehicle declaration is signed off M C-TPAT 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

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 47
Section Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations Y N N/A cat

10.4 Driver instructions on entering/departing the site (Driver Manual issued by


Intermodal operator)

10.4.1 Is there a drivers manual distributed to all drivers in a language they can understand I
?

10.4.2 Does the drivers manual contain detailed instructions regarding :


10.4.2a - BBS principles ? RC
10.4.2b - incident reporting ? I RC
10.4.2c - near miss reporting ? I RC
10.4.2d - use of seat belt ? I RC
10.4.2e - use of mobile phone ? I RC
10.4.2f - use of drugs and alcohol ? I RC
10.4.2g - actions to be taken in an emergency ? I RC
10.4.2h - security ? I RC
10.4.2i - identification of the product ? I C-TPAT RC
10.4.2j - verification that all prescribed documentation, including the written instructions M RC
for drivers (transport emergency cards), is on board of the transport unit ?
10.4.2k - verification of the presence of all the (safety) equipment as required by M RC
legislation and prescribed in the written instructions for the drivers (IMDG code
goods ) ?

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

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 48
Section Administration
11
IMPCAS Specific Questions
11.1 Records Y N N/A cat

11.1 Records
11.1.1 Are records of all transport/handling orders (receipts and deliveries) kept, including :

11.1.1a - order identification ? I


11.1.1b - container identification and job number ? I
11.1.1d - actual loading date, loading time and loading site ? I
11.1.1e - quantity received and delivered ? I
11.1.1f - requested delivery date, delivery time and delivery site ? I
11.1.1g - actual delivery date, delivery time and delivery address ? I
11.1.1h - cleaning documents/certificates ? I

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 49
Section Site Inspection
12
IMPCAS Specific Questions
12 Site Inspection Y N N/A cat

12.1 Office and Buildings


12.1.1 Is the visible condition of the buildings of an acceptable standard ? I
12.1.2 Is housekeeping at a good standard (clean, tidy, paintwork, etc.) ? I
12.1.3 Are emergency exits marked on buildings and easily accessible? M
12.1.4 Are signs for site identification and public safety in place ? I
12.1.5 In case of emergency, is there an assured method for safe evacuation of all M
personnel and is this publicly placarded ?
12.1.6 Is the emergency assembly point clearly placarded ? M
12.1.7 Are fire extinguishers marked with the inspection and maintenance data easily M
12.1.8 Are the first aid posts clearly indicated, easily accessible and appropriately stocked M
to ensure prompt treatment ?
12.1.9 Is there a sufficient site lighting system ? I
12.2 Depot and Parking
12.2.1 Is the site paved according to the requirements and the activities that are taking I
12.2.2 Is the condition of roadways and parking area of an acceptable and safe standard ? I
12.2.3 Are there designated walkways away from truck traffic ? I
12.2.4 Is the site location suitable for vehicle access and is there easy movement of trucks I
12.2.5 If loaded trailers are parked at the site, are landing gear support pads used when I
there are weaknesses in the parking surface ?

12.3 Internal handling transfer of packaged goods


12.3.1 Are the correct product details available during internal handling transfer and I
12.3.2 temporary
Have storage ? involved in the handling transfers of goods received
the employees I
12.3.3 appropriate
Do traininginvolved
the employees ? in the handling transfer of goods have adequate I
12.3.4 personal protection ?
Is the transfer and temporary storage of liquid materials carried out in an area with I
12.3.5 impervious
Does surface have
the company ? equipment available to handle accidental release/escape of I
12.3.6 product
Does the? company have a specific written procedure for the transfer and temporary I
12.3.7 storage of goods
Is the transfer ?
of goods carried out by using adequate and safe equipment ? I
12.3.8 Are caution signs installed (no smoking, eye protection, helmet, etc.) ? I
12.3.9 Are fixed eyewash/safety shower systems available in the work area ? I

CFS Audit Questionnaire


Rev 2: IMPCAS 10/2012 (C)2012 Chemical Distribution Institute 50
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.1 Management Responsibility

1.1.1 Company Policies


1.1.1.1a-g The policy statement(s) must be clear and unambiguous concerning management’s commitment to
the QHSSE & D & A which meet customer's, statutory and other requirements at all times. There
should be evidence that the policy is reviewed and kept up to date.
1.1.1.2a BBS (or an equivalent programme) aims to increase safety during transport and related
loading/unloading activities by positively influencing the behaviour of operators/drivers through
observation, coaching and communication. It is envisaged that BBS programs are an integrated part
of the company QHSSE policy. Verify if specific reference is made in the policy to Behaviour Based
Program
1.1.1.2b Verify if it is explicitly stated in the D & A policy that the use/or being under the influence of any drug
or alcohol is prohibited during working hours.
1.1.1.2c Protecting people, safeguarding the integrity of high value and hazardous products against loss by
intentional destruction or theft, and proprietary information in the custody of a logistic service
provider is essential. Verify whether the importance of these objectives are specifically mentioned in
the policy.
1.1.1.2d Is there evidence that the policy(s) are communicated to all staff and contractors and others who
need to know?
1.1.2 Roles & Responsibilities
1.1.2.1 To achieve a positive score, there will be an organisation chart for the site showing individuals' job
titles and to whom they are responsible. These titles should be supported by job descriptions which
are relevant to the work carried out. The company should have formally designated representatives
for operational safety & occupational safety & health, environmental protection, security and quality.
Where this particular question is categorised as “I” bear in mind that in some countries a Safety
Manager is a legal obligation. In a larger company these may be full-time jobs but it is recognised
that in smaller companies‚ these roles may be part of another job. The posts need not have this
particular management titles. The responsibility for the QHSSE management systems within the
Company and the responsibilities for the effective operation and maintenance of these systems
should be clearly defined and assigned.
1.1.2.2 Has local Senior. management signed off the HSSE policy statement, initiated HSE cases and set
HSSE objectives and targets? Do documents prove an active leadership by taking the lead in e.g.
presentations, interventions, discussing HSSE in staff meetings as well as with contractors?

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.

CFS G-N to Audit Questions


Rev 2 : IMPCAS 10-2012 (C)2012 Chemical Distribution Institute 51
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.2 Personnel

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.

CFS G-N to Audit Questions


Rev 2 : IMPCAS 10-2012 (C)2012 Chemical Distribution Institute 52
Section 1 Container Freight Station Management
IMPCAS Core Questions
1.3 QHSSE Performance Analysis

1.3 Non-conformances Reporting, Investigation, Analysis and Corrective Action


1.3.1 Data should be available at every phase of the business from identifying new business through to
customer reaction and feedback. The collection and analysis of data can indicate means of
improving the service or conversely, can detect the onset of a reduction in the quality of service
before it becomes a major issue. To verify the satisfactory operation of the reporting system, several
sources of information should be checked such as reports to insurance companies, customer
complaints and fines, feedback from internal observations (e.g. drivers).

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 QHSSE Trend Analysis and Improvement Objectives

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

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Section 1 Container Freight Station Management
IMPCAS Core Questions
1.4 Management Review

1.4.1 Management Review

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 Internal Audit

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.

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Section 1 Container Freight Station Management
IMPCAS Core Questions
1.5 Insurance

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.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.1 Risk Management

2.1. Risk Management


Please note that Risk Management related to Security is covered more explicitly in section 3 and
Risk Management related to Intermodal Security is also covered in section 7.
A documented system should be in place to describe how risks associated with the companies
operations are evaluated. The risk assessment should assess the risks from both safety and health
hazards and security threats. The process should consider statutory and legislative requirements and
risks resulting from operational activities. The risk assessment and management system should
examine the following questions:
- what are the hazards?
- what can go wrong?
- what is the probability that something will go wrong?
- what is the potential impact on people, property and the environment?
- what measures should/can be taken to reduce the identified risks as much as possible?
Risk management should be regarded as a continuous process. The process should be repeated at
regular intervals, based on practical experience and incident evaluation. High risk activities should
receive more frequent reviews. A risk assessment should also be carried out each time there is a
significant change in the operational activities (e.g. handling of new products, use of new equipment,
changes in operating procedures). New projects should be evaluated at an early stage. The risk
assessments for new projects should be carried out in close co-operation with the chemical
suppliers.
2.1.1 To score a ‘yes’, a documented system should be in place (see main comment above) to assess and
manage the risks of both existing and new operations. Check if the process of risk assessment is
repeated at regular intervals (at least annually) for existing operations and takes into account
practical experience obtained during the operations and from incident evaluations. Check if a risk
assessment has been carried out each time there has been a significant change in the operational
activities and for every new project. Check the risk assessment report of two recent new activities or
projects.
2.1.1a The auditor should identify any new products recently carried, at the same time any new routes that
products are transported over. These activities should be verified by a risk assessment. The auditor
should ask to see the DGA report (if a DGA is required) (may be separate from main DGA Annual
report) that assesses the safety and environmental impact of new products before carriage or new
services that are planned.
2.1.1b From conversation with auditees identify any work practice changes, check whether this warrants a
risk assessment to mitigate the operating risk, has a risk assessment been conducted ?

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)

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.2 Safety

2.2.1 Personal Protective Equipment (PPE)


Please note that this section deals with PPE used by "OWN Personnel" only. The controls over PPE
of contract-personnel are covered in the section on subcontracting.
2.2.1.1 Verify that an adequate procedure exists and is implemented.
2.2.1.2 The result from equipment checking should be documented, showing the inspection date, condition,
name of the inspector and comments. The auditor should ask to see an issue register for PPE to
employees, this can then verify defective PPE equipment was repaired before issue. The register
should also show the frequency of checks on PPE to verify condition.
2.2.1.3 For some particularly hazardous substances specialised equipment is required, for example: suitable
respiratory protective devices, antidotes or decontaminants are required. Check whether an analysis
has been made on the products the company is handling and that the need for specialised
equipment has been determined. Check that instructions for use have been made available to
individuals using the equipment and any relevant training has been conducted.

2.2.1.4 Is there evidence that equipment is used?

2.2.2 On Site Emergency & Security Preparedness and Response

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

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Section 2 Safety, Health, Security and Environment
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2.3 Occupational Health and Safety

2.3 Occupational Health and Safety


2.3.1 - 2.3.9 Check that the requirements stated in 2.3.1 - 2.3.9 inclusive are adequately addressed. Where
necessary samples should be selected
2.3.2 A product acceptance procedure should be in place asking for the product safety data before the
product is handled. Product safety data should be supplied by the manufacturer. Check the
accessibility of this information at the site (e.g. a file with the Safety Data Sheets of all the products
transported or handled). Check at random the available information for a few products.
2.3.10 CTUs delivered as nominally empty ready for loading frequently contain debris, used dunnage and
cargo residues from previous loads. Cargo residues can be hazardous to persons entering the
container.
2.3.11 - 13 CTUs delivered for unloading frequently contain levels of in transit fumigant gas that can be
hazardous to persons entering the unit. CTUs should be checked for gas or vented prior to entry.
Check documentation for procedures

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Section 2 Safety, Health, Security and Environment
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2.4 Environment

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.

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Section 2 Safety, Health, Security and Environment
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2.5 Spill Prevention and Control

2.5 Spill Prevention and Control

2.5.1a - c Check that the requirements stated in 2.5.1a-c inclusive are adequately addressed. Where
necessary samples should be selected

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Section 3 Security
IMPCAS Core Questions
3 Security

3.1 Security standards and procedures


3.1.1 Verify that the company has appointed a competent person with appropriate qualifications with the
necessary authority to act as the responsible person for security. Look for records of any training)
3.1.2 Has the company developed a security plan, based on its security risk assessment, which includes
all ADR/IMDG requirements and implemented security arrangements such as those in ISO/PAS
28000, WCO Framework of Standards and other requirements to which the organisation subscribes.
3.1.3a-d Does the company Security Plan include :
- a regular review of the operations and an assessment of potential vulnerabilities including :
- measures identified / taken to reduce security risk
- reporting system must be in place for security threats and for security related Near Miss / Incident
reporting .
- security must be integrated in the regular training sessions.
- look for an annual review report, including evaluation and test results.

3.2 Site security


3.2.1 Check fences, gates and 24hr lighting during your site visit. Establish that physical barriers serve the
purpose they are designed for.
3.2.2 Give a score for any effective control method, e.g. security guard, electronic card entry system,
records kept of visitors etc.
3.2.3 Check the availability and the use of periodic inspection sheets or security check lists and verify the
reporting of incidents and its remediation.

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.

3.3 Security Training


3.3.1. There must be a list of all personnel that require security training. The nature of the security
knowledge to be covered by the training must be in line with the HCDG plan and security risk
assessment. The auditor should recognise that the training required will depend on the vulnerability
of the site, the nature of the threats and goods being shipped. The competence, experience and
security training required will reflect this. The minimum training, however, should include the
requirements in 3.3.1a - f inclusive.

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Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care®

4.1 Quality System


4.1.1 The Quality System, operated by the company must be documented. This documentation is
important for controlling quality. The QS documentation should, as a minimum, comply with the
requirements of ISO 9001:2000. For a company being certified against ISO 9001:2008 the Auditor
should convince themselves that the scope of the certification covers all relevant processes and that
the depth of the system is adequate.

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.

4.2 Purchasing of critical Materials and Services


4.2.1 Select a sample of purchase orders to verify conformance with this requirements

4.3 Control of purchased materials and services


Note: The use of contractors by the Operator may be critical to cost, efficiency and safety of the
service provided. The procurement of products or services should be given the same level of
planning and control as internal activities.
4.3.1 Confirm by tracing at random how suppliers of equipment and/or services have been selected.
Examples should be taken at random and checked.
4.3.2 Verify that an adequate goods inspection process is in place and implemented which reflects the
criticality of goods. Examples should be taken at random and checked.

4.4 Suppliers of critical goods and services


4.4.1 The auditor should check that any recorded non conformances are investigated as per Section 1.3.

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.

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Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care®

4.6 Responsible Care®

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.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.1 Choice of logistic solutions

5.1 Choice of Logistics Solutions


5.1.1 Look for a documented process including a risk assessment covering SHEQ&Sec elements, for
defining and choosing the logistics solution for the assigned "Transport Service" orders. Verify a
sample of current or completed assignments, the process for selecting the parties and persons
involved, communication lines and interfaces, schedules and routes, alternative solutions with
considerations on SHEQ&Sec requirements. This may include choice of transport mode (road, rail,
barge, sea, air) and respective means of transport (MOT) like type of containment and equipment.

5.1.2a-d For this sample of transactions, look for a risk analysis covering the relevant QHSSE elements.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.2 Supply Chain Management

5.2 Supply Chain Management


5.2.1a-d Verify through a sample of transactions that QHSSE objectives have been set and formally
communicated to all partners. Look for evidence from meetings and communications that all
providers involved in the supply chain have been considered. This includes carriers of all modes of
transport, pre- and onward carriage and any partner in charge of handling and transhipment.
5.2.2 Look for documentary evidence that company's supply chain partners' objectives and targets have
been achieved within the required timescales.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.3 Supply Chain Integrity

5.3 Supply Chain Integrity


5.3.1 Verify through a sample of transactions how the company traces and follows current status/location
during transport and transit. In larger companies, effective control of the status of shipments along
the supply chain could be based on IT-technologies like barcodes, RFID (Radio Frequency
Identification) or SCEM (Supply Chain Event Management). Look whether the process description
covers the complete supply chain.
5.3.2 Verify how the company transmits customer instructions to its partner and subcontracted service
providers. Look for evidence that all logistic partners involved in the business are informed
accordingly about the customer's requirements. E.g. verify that signed requirement profiles have
been relayed to all.
5.3.3 Look for a formal reporting process for on time - in full (OT/IF) delivery. Follow up a sample of
changes to verify that changes requested by logistics chain partners have been reviewed and
implemented.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.4 Subcontracting Services

5.4.1 Subcontracting policy

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).

5.4.2 Appointed subcontractors


5.4.2.1 Verify, by sample of current transport orders, that all logistics providers are listed on the approved
suppliers list.
5.4.2.2 Are the obligations placed on logistics partners (e.g. other intermodal operators to whom the
movement of goods is subcontracted) clearly communicated in written agreements with those
partners?
5.4.2.3 All drivers, whether subcontractors or not, shall be trained by their employer or the main contractor
(the company). Evidence of training in accordance with other requirements in this documents shall
be verified.
5.4.3 Unplanned spot services by subcontractors
5.4.3.1 Spot subcontracting is defined as sudden calls upon an unknown subcontractor from the "yellow
pages". Verify that spot subcontracting is not practiced in the base-case, by comparing actual
transport orders with the list of approved subcontractors. Exceptionally, when spot subcontracting
has been used for peak demands or special orders, there must be a specific agreement from the
customer Chemical Company. Look for evidence that the minimum requirements have been
communicated and verified.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.5 Performance monitoring of logistics partners

5.5.1 Performance criteria


5.5.1.1a - r Review a sample of subcontractors' files and check that the requirements are contained in logistics
service providers' (subcontractors') service agreements.
5.5.1.2a - d Flexible hoses are critical equipment as hose breaks could cause severe health and environmental
damage. All hoses should be uniquely identified, labelled and inventoried in a database to facilitate a
maintenance/testing programme and follow-up. Verify the testing procedure and score a "Yes" for
each item reflected in the written procedure and check also whether implemented.

5.5.2 Performance monitoring process


5.5.2.1-3 For a sample of logistics partners select some evaluation and performance reports and look for
evidence that these have been evaluated. Establish that dialogue/communications have, and
continue to take place to ensure improvement actions are implemented and monitored. Look for
evidence that the company has analysed its partners' reports from the CDI/SQAS databases or
alternatively has obtained extracted reports directly from the assessed companies.

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.

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Section 6 Equipment
IMPCAS Specific Questions
6.1 Equipment Specification

6.1 Equipment Specification


6.1.1 Look for a written procedure describing the purchase/lease for equipment to ensure it includes a
requirement for standardised technical specification for each type of equipment including references
to any relevant regulatory standards.
6.1.2a-i Check the specifications for a sample of recently purchased/leased equipment to verify that they
include the necessary specifications as detailed in 6.1.2a - i inclusive

6.1.3 Ask how, and by whom. Look for records and valid certificates.

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Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance and Calibration

6.2.1 Equipment Inspection and Maintenance (Service)


6.2.1.1 - 2 Verify that there is a documented programme for inspection, maintenance and calibration of
equipment described
6.2.1.2a-d Check for a clearly documented procedure addressing each of these questions. Verify that the
documented procedure is being implemented for equipment found to be non conforming, particularly
those items which have been put into service or used with faults or overdue for inspection. This
procedure should include the corrective actions to be taken when non conforming equipment is
used.
6.2.2 Lifting Equipment
Verify from completed checklist or equivalent record in the event that servicing is contracted out.
Rolling Equipment
6.2.3.1a-e Ask to see copies of procedures. Each item should have a written procedure. Check records
ensuring procedure is implemented.
6.2.3.2a-d Verify from records.
6.2.3.3 Establish the basis of reporting to a responsible person within the company. The decision to
authorise continued use must be at the appropriate management level. Authorisation needs to be in
writing and sighted.

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Section 6 Equipment
IMPCAS Specific Questions
6.3 Equipment Inspection, Maintenance and Calibration

6.3.1. Statutory Examination and Testing


6.3.1.1 Check documented procedure clearly references the CSC.
6.3.1.2 Check records of test certificates for dates of most recent examinations and tests.
6.3.1.3a-e Verify from check lists or as items on the computer program or from test certification.
6.3.2 Identification and Calibration of Measuring & Test Equipment
6.3.2.1 Calibration, if performed in-house, should be undertaken by persons who have been properly trained
and are working to documented procedures. Alternatively, calibration may be undertaken by a
qualified contractor certificated to national standards. In this case, a formal agreement specifying
the requirement for, and the frequency of, calibration should exist between the operator and the
contractor. Ask to see a copy of the procedures and a list of items identified for calibration.

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.

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Section 6 Equipment
IMPCAS Specific Questions
6.4 Equipment of Partners

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.

6.4 Equipment of Partners


6.4.1 Look for evidence from assessments and visit reports that the sampled subcontractors have adopted
the statutory requirements and industry standards (as specified in the purchase specification of
section 6).
6.4.2-5 Look for evidence from assessments and visit reports.

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Section 7 Container Freight Station
IMPCAS Specific Questions
7.1 Responsible Care Management System
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.
Stakeholders: Person or persons impacted or potentially impacted by the organization's operations.
These may include employees, stockholders, neighbours, emergency responders, other industries,
competitors, commercial partners, public at large, NGOs, regulators, and anyone else with a
personal stake in the organization's operations.

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Section 7 Container Freight Station
IMPCAS Specific Questions
7.1 Responsible Care Management System

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.

Stakeholders: Person or persons impacted or potentially impacted by the organization's operations.


These may include employees, stockholders, neighbours, emergency responders, other industries,
competitors, commercial partners, public at large, NGOs, regulators, and anyone else with a
personal stake in the organization's operations.

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Section 7 Container Freight Station
IMPCAS Specific Questions
7.1 Responsible Care Management System
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.

Stakeholders: Person or persons impacted or potentially impacted by the organization's operations.


These may include employees, stockholders, neighbours, emergency responders, other industries,
competitors, commercial partners, public at large, NGOs, regulators, and anyone else with a
personal stake in the organization's operations.

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Section 7 Container Freight Station
IMPCAS Specific Questions
7.1 Responsible Care Management System
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.

Stakeholders: Person or persons impacted or potentially impacted by the organization's operations.


These may include employees, stockholders, neighbours, emergency responders, other industries,
competitors, commercial partners, public at large, NGOs, regulators, and anyone else with a
personal stake in the organization's operations.

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Section 8 Intermodal Security
IMPCAS Specific Questions
8 Intermodal Security

8.1 Security Plan


8.1.1 Check that the company gives its logistics service providers (subcontractors) the information
necessary for it to carry out the contracted service and ask how instructions are communicated to
whilst retaining the necessary level of confidentiality.

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.

8.1.3 Verify by taking samples.

Security during intermodal transport moves

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 Legal requirements for High Consequence Dangerous Goods (HCDG) :

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 Best practices for transport security of HCDG :

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.

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.1 Operating instructions

9.1 Operating Instructions


9.1.1 The site should have all the necessary operating and environmental licenses for all the activities
carried out at the site including, but not limited to: fuel facilities, maintenance workshop, parking of
trucks, temporary storage of goods, etc. The assessor will check the available licenses against the
site’s activities.

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.

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.2 Customer Interface

9.2 Customer Interface

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.

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations

10.1 Order Planning


10.1.1 The assessor should review the documented procedures and give a positive score if the key
elements are covered, e.g. equipment maintenance schedules are not conflicting with order
execution schedules.
10.1.2 Verify by reviewing relevant information and instructions, detailed in 10.1.2a - 10.1.2i.

10.2 Order instructions for multimodal shipments


10.2.1 Check documented procedures and look for evidence that the multimodal operations are handled,
10.2.3 planned and controlled as per conditions required in 10.2.2.1a - 10.2.4.1l

10.3 Examples taken from the IMDG code chapter 5.4.2.1


- proper shipping name
- UN number
- hazard labels
- subsidiary hazard label(s) if required
- marine pollutant mark (if relevant)
- orientation labels (if relevant)

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations

10.4 Driver instructions (Driver Manual issued by Intermodal operator)

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.

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Section 11 Administration
IMPCAS Specific Questions
11.1 Records

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

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Section 12 Site Inspection
IMPCAS Specific Questions
12 Site Inspection

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.

12.1 Office, buildings and site in general


When the company is only operating an office building, the site inspection is limited to sub-section
12.1.1 - 12.1.9 and the remainder of Section 12 may not be applicable. Otherwise, the "office and
site" questions refer to all buildings/infrastructure of the site.
12.1.1 - 9 Verify by conducting a site tour.

12.2 Depot and parking


12.2.1 Check that all site surfaces where product/equipment handling and movement take place, are made
of stable materials (bricks, concrete, asphalted, etc. to avoid holes that could cause safety hazards).
Where hazardous liquids are handled the surface should be impervious.

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.

Check from documentary evidence that a procedure is in place.


This should be a visual check of equipment to verify from documentary evidence sighted during the
audit.

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