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					                     Canadian Chemical Producers' Association




                                    Responsible Care®: A Total Commitment




                                                Re-Verification

                                                           For


                    ATOFINA CANADA INC.
                                    September 7th and 8th, 2000

                                 ® Responsible Care is a registered trademark of
                                 The Canadian Chemical Producers' Association

                                                        DISCLAIMER

This document has been produced by a team convened by the Canadian Chemical Producers' Association (C.C.P.A.) to
provide guidance to the above company, as a member of the association, in meeting its obligations under Responsible Care®.
Although C.C.P.A. members are expected to share the results of this guidance with interested parties, neither the association,
its member companies, their employees, consultants and other participants in this study accept any responsibility whatsoever
for consequences resulting from its use or application. It is the responsibility of the C.C.P.A. member company which is the
subject of this report to interpret and act on the findings and recommendations as it sees fit, and any member company,
organization or person using this document does so at their own risk.




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TEAM CONCLUSIONS AND EXECUTIVE SUMMARY

The Responsible Care® re-verification for ATOFINA Canada Inc. was conducted on
September 7th and 8th, 2000. The process was based on the C.C.P.A. Responsible
Care® Re-verification protocol. During the re-verification a four-member team including
a local community representative, conducted interviews and site inspections at the
ATOFINA manufacturing site and the associated Multimodal Logistics warehouse in
Mississauga. Based on data collected during the re-verification process, including
interviews with appropriate stakeholders, the team judged that ATOFINA Canada Inc.
continues to have effective management systems to meet the Responsible Care®
codes and ethic established in the initial Responsible Care®-in-Place verification. In
addition these management systems have an element of continuous improvement
demonstrated during the re-verification visit.

The team was impressed with the professionalism and commitment to the Responsible
Care® ethic demonstrated by all managers and staff.            Company noteworthy
accomplishments, best practices and extra miles will be described in the body of the
report.

The team also noted several opportunities for improvement that will be noted in the
report.

PLEASE NOTE:        the re-verification protocol requires team comments on
exceptions or findings. Most company management systems that meet or exceed
the codes and ethic of Responsible Care® will not be described in detail.




Cameron D. Dillabough
Re-verification Team Leader




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INTRODUCTION

This report contains the comments and recommendations of the re-verification team.
Bold type will be used to identify company best practices and extra-miles. Bold
italics are used for any significant findings the team considers must be
addressed before the company can be considered to have completed the
requirements of Responsible Care® Re-verification as stipulated by the Canadian
Chemical Producers' Association. An arrow bullet icon identifies opportunities for
improvement () and will be listed in the appropriate areas of the statement on
Management Systems.


A.    COMPANY AND RE-VERIFICATION OVERVIEW

The Canadian Chemical Producers' Association (C.C.P.A.) Responsible Care® Re-
verification Team addressed various Company Management Systems to verify whether
ATOFINA Canada Inc.:

      1. Continues to have effective management systems to meet the Responsible
         Care®-in-Place principles and codes as established in the initial verification
         [while member companies are expected to maintain management systems for
         all codes, the areas of particular focus will include TransCAER, outreach,
         route risk assessment, carrier evaluations, process risk assessment and
         communications, process safety management and product stewardship, plus
         other code elements identified by the C.C.P.A. and the re-verification team].

      2. Has demonstrated that it has effectively addressed all concerns, suggestions
         and recommendations raised in the initial verification and has shared the
         results of this verification with the local community.

      3. Has adequately addressed significant issues and incidents that have arisen
         since the initial verification.

      4. Has, as part of its management systems, processes, including performance
         indicators, to ensure continuous improvement in its performance. Critical
         areas include emissions reduction (N.E.R.M.), Occupational Health and
         Safety (S.H.A.R.E.), Transportation Incidents (T.I.M.), process-related
         incidents, product stewardship, stakeholder involvement and, most
         importantly, priority areas identified by the Member Company and C.C.P.A.

      5. Has identified, through an effective and proactive public dialogue process,
         priority areas of concern and has established effective methods, targets and
         timelines for addressing these concerns.

      6. Has demonstrated significant improvement in performance in at least the
         priority areas of concern.

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THE C.C.P.A. RE-VERIFICATION TEAM

                                  Affiliation                       Representing

Cameron D. Dillabough             Consultant                        Industry
(Team Leader)

Robert Kennedy                    Consultant                        Industry

Kristina Lee                      External Member                   Community at
                                                                    Large

Erika Kadar                       Community                         ATOFINA Oakville
                                  Representative                    Location
                                                                    Community


PROCESS

The re-verification was based on documents submitted to the team by ATOFINA
Canada Inc. (ATOFINA). The team then conducted two-day visit to the Oakville
manufacturing site and the associated Multimodal Logistics warehouse in Mississauga.
Information was compiled from interviews with company managers and employees,
document reviews, site inspections and interface with external stakeholders. A four-
member team, including three members appointed by the C.C.P.A. and a community
representative selected by the West Oakville Community Liaison Panel, conducted the
re-verification. The re-verification was conducted utilizing the C.C.P.A. Re-verification
protocol.


KEY COMPANY CONTACTS:

LEADERSHIP:

*Bob Miller                       -      President and C.E.O.
*Jim Hilborn                      -      President, PC&P
*Steve Copeland                   -      Responsible Care® and ISO Co-coordinator
*Cam Cossitt                      -      Oakville Plant Manager
*Robert Roth                      -      Technical Manager
Virgil Zanfir                     -      Technical Service Co-coordinator
Frank Delaat                      -      Sales Manager, Peroxides

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Stuart Morley                     -      Maintenance Supervisor
Dave Landry                       -      J.H.S.C. Union Representative
Kari Hocking                      -      J.H.S.C. Co-chair
Dan Parent                        -      Multimodal Logistics
Keith Thacker                     -      Multimodal Logistics

*Denotes code co-coordinators

The team utilized the top-down interviewing approach described in the Responsible
Care® improvement protocol. The questions focused on management processes
rather than procedural detail and tested for effective management systems and
attitudes to ensure an understanding and adherence to the codes and ethics of
Responsible Care®.


ATOFINA CANADA INC.

In 1997 a Responsible Care®-In-Place verification was attained by the company then
known as Elf Atochem Canada Inc. Since that time there have been several changes
at the Oakville site principal being the acquisition of Elf Atochem by Total Fina resulting
in the formation of the ATOFINA Chemicals Inc. business group of which ATOFINA
Canada Inc. is a member. The other notable change was the promotion of Bob Miller to
President and C.E.O. of ATOFINA Canada Inc. A hydrogen peroxide manufacturing
site a Bécancour, Québec has also been acquired but was not part of the re-
verification. This location is in the process of acquiring Responsible Care®-in-Place
verification.


B.    ROUND ONE REPORT

The Responsible Care®-in-Place verification was held in September 1994. At that time
there were two findings in the area of benchmarking community awareness and
process risk management reviews. A subsequent verification team visit took place in
January 1997 and at this time management systems had been installed to address the
1994 findings. The 1997 final report also listed four opportunities for improvement.

Upon a review of these reports during the re-verification visit the team was in
agreement that all required actions from both the 1994 and 1997 reports had been
completed.


C.    STATEMENT ON THE ETHIC




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The Responsible Care® ethic within the company is well understood and a part of all
business and functional activities. Senior management have demonstrated a strong
commitment to Responsible Care® by implementing systems to ensure all employees
are knowledgeable and committed to Responsible Care®. Senior management also
set an example by active participation in C.C.P.A. leadership groups and sub-
committees. Bob Miller, President and C.E.O., was instrumental in assisting the Vinyl
Council of Canada in the development of the Council’s environmental management
plan.


D.    EMPLOYEE AWARENESS

The team found employee awareness and commitment to the Responsible Care® ethic
to be very strong throughout the Oakville location. New employees are introduced to
Responsible Care® during orientation and refresher training and participation in various
Responsible Care® activities continually reinforce the principles of Responsible Care®.


E.   MANAGEMENT SYSTEMS

The Responsible Care® management system in place at ATOFINA Canada Inc. is
linked to the company ISO management system. This ISO link provides a methodology
to develop policies, regularly review Responsible Care® performance and provide a
system for corrective action. The corrective action tracking system is a very effective
method of monitoring overall Responsible Care® performance.               An internal
Responsible Care® audit system is also utilized to monitor Responsible Care®
performance. Goals and objectives, including Responsible Care®, are developed and
tracked on an annual basis. These annual goals can be developed by ATOFINA
Canada Inc. or be developed to support corporate Responsible Care® objectives.
There is also a focus on employee training within the organization.

 There is an opportunity for improvement to ensure that all documents not ISO
  controlled have a review and obsolescence date.

F.    C.C.P.A.’s REQUESTED AREAS FOR TEAM FOCUS

TRANSCAER (ROUTE RISK ASSESSMENT AND CARRIER EVALUATION)

Good management systems are in place to address the TRANSCAER code
requirements and the Responsible Care® ethic expectations. ATOFINA Canada Inc. is
one of three C.C.P.A. companies who have taken responsibility to revitalize the
C.C.P.A. TRANSCAER effort on the Highway 401 corridor through the metropolitan
Toronto area. From a functional perspective transportation emergency response plans
are in place and have been communicated and tested. Route Risk Assessment for
high hazard shipments have been completed.


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 The company’s three-year-old route risk assessment should be reviewed to
  determine if all previous risk criteria still apply.

 Warehouses, other than Multimodal Logistics, were last reviewed from a risk and
  product content perspective in 1997. There is an opportunity to review third party
  warehousing, from a risk perspective, on an annual basis.

 Although ATOFINA does not operate the Multimodal warehouse, the team felt that
  there was an opportunity to offer help from a worker safety viewpoint. During our
  tour the team noted air cylinders in storage that were not secured and were
  informed that there is not a system to regularly check operators that work alone in
  the warehouse.


PROCESS RISK ASSESSMENT

There are risk assessment systems in place that are appropriate with the level of risk at
this facility. Corporate hazard reviews are performed on a five-year cycle on critical
processes and corrective actions are tracked both locally and at a corporate level.


RISK COMMUNICATION

Risk communication, including the worst-case scenario (WCS), for the Oakville facility
has been completed. This process included local emergency responders and local
industrial neighbours. A WCS has been completed for the Multimodal Logistics location
and Multimodal management is in the process of developing a communication plan for
their industrial neighbours.


COMMUNITY DIALOGUE PROCESS

Appropriate community dialogue management systems are in place. These systems
include an open house and community information brochures.              ATOFINA has
developed a very active West Oakville Community Liaison Panel that includes their
local industrial neighbours. Through constant exposure to the Responsible Care®
codes and ethic ATOFINA is slowly instilling a Responsible Care®-like ethic in its non-
C.C.P.A. industrial neighbours and is assisting their one C.C.P.A. industrial neighbour
to achieve Responsible Care®-in-Place verification. The re-verification teams’ meeting
with the West Oakville Community Liaison Panel was very positive and ATOFINA
Canada Inc. is to be commended for their efforts in this area.

The ATOFINA West Oakville Community Liaison Panel is somewhat unique in make-up
and discussion subject matter. As a method for enhancing the West Oakville
Community Liaison Panel process the team would make the following suggestions:
Develop a simple annual report that would track the past years’ progress and future

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goals for the West Oakville Community Liaison Panel. If the opportunity exists, the
West Oakville Community Liaison Panel should endeavour to enlist student members
as a method of spreading the Responsible Care® ethic and if company policy permits
include a West Oakville Community Liaison Panel member in the company internal
Responsible Care® audits as a method of educating members on the requirements of
Responsible Care®.

The team viewed as an extra-mile the work of ATOFINA Canada Inc. in the areas
of West Oakville Community Liaison Panel make-up and objectives and the work
of Bob Miller and the other code co-coordinators in promoting the ethic of
Responsible Care® with other non-C.C.P.A. West Oakville Community Liaison
Panel member companies and recruiting new C.C.P.A. member companies.


PROCESS SAFETY MANAGEMENT

Appropriate process safety management (PSM) systems are in place at ATOFINA
Canada Inc. Corporate audits are completed on a tri-annual basis and corrective action
is tracked at the local and corporate level. The level of employee safety training is very
high and the company employs a job safety analysis (JSA) task observation process as
one of the principle methods of maintaining and improving the company’s safety
performance.

 An opportunity for improvement exists to ensure that all supplier material safety data
  sheets (MSDS) are regularly updated.

 An opportunity for improvement exists to cross-reference JSA procedures with ISO
  work instruction documents or combine the JSA and ISO work instructions in one
  “total job analysis” management system.


PRODUCT STEWARDSHIP

The management system for product stewardship complies with all requirements of the
Responsible Care® product stewardship code. This system includes a new product
authorization process that includes all the appropriate environmental, health and safety
decision gates. Internal Responsible Care® audits review the distribution aspects of
product stewardship and Sales and Marketing managers’ performance reviews include
Responsible Care® and product stewardship components.

 An opportunity for improvement exists to include company product stewardship
  initiatives and requirements in the internal Responsible Care® audits including the
  expectations of distributors and customers, receipt of MSDS’s and other product
  stewardship metrics.



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EMERGENCY RESPONSE

Emergency response management systems are in place and provide for yearly training
of emergency response technical advisors and contract responders. Annual site
evacuations and training with contract responders are critiqued and improvement
opportunities provide an element of continuous improvement for the emergency
response managements systems.

 The last integrated test of the community emergency plan took place in 1996. In
  spite of regional problems with organizing this type of integrated response there is
  an opportunity for ATOFINA to update and review the sites’ integrated emergency
  response and crisis management plans.


ENVIRONMENTAL EMISSIONS

There are management systems in place to track, monitor and reduce environmental
emissions. Volatile organic compound emissions are too low to report to the N.P.R.I.
registry.


BUFFER ZONE POLICY

While corporate engineering standards and local site management initiatives on zoning
changes and land use cover most components of a buffer zone policy, such a policy
does not exist. It is a Responsible Care® requirement that a signed buffer zone policy
be in place. The team strongly recommends that ATOFINA expedite the creation of a
signed buffer zone policy.


HISTORICAL WASTE SITES

There are no historical waste site concerns at the ATOFINA Canada Inc. Oakville site.


ON-SITE CONTRACTOR SELECTION

There are management systems in place to select, monitor and critique on-site
contractor’s performance.


G.    LIFE CYCLE IMPACTS

From a corporate perspective life cycle analysis projects are in place for several product
raw materials that have been identified as having potential long-term environmental

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impact. This research is being conducted solely by ATOFINA or as part of funded
research by industry associates. Development of new products is controlled by the new
product authorization management system that has a component addressing potential
life cycle impacts.


H.    COMPANY REQUESTED AREAS OF TEAM FOCUS

A. COMMENTS ON CROSS-REFERENCE MATRIX

During the re-verification visit Kris Lee made cross-referencing notes that were given to
Steve Copeland. As a long-term project the team would suggest that the number of
documents be reduced by incorporating all procedures into one system and the ISO
system would be the most logical. By utilizing an ISO-based system the only cross-
referencing would be within the wording of the actual standards, policies and
procedures and regular review and updating would be automatic.

B. MULTIMODAL LOGISTICS WAREHOUSE

During the team’s visit the Multimodal managers were encouraged to practice the codes
and ethic of Responsible Care® especially in the area of community outreach. The
team also listed some specific concerns to the warehouse manager and listed others in
this report. Because of the unique relationship between ATOFINA and Multimodal
Logistics the team would suggest a regular “first-line” manager liaison as a method of
exposing Multimodal personnel to the various aspects of worker health and safety and
community outreach.




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COMPANY COMMENTS




                   11/12/2000 - Final

				
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