Self Assessment and Verification as integral elements of

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					“Self Assessment and
Verification as integral
elements of Responsible Care:
Approaches in Europe to date.
A company view”
         Harry Spaas
       Dow Europe GmbH

               Pg. 1
Cefic agreement based on Responsible
Care review (1)
    Key recommendations from this review:
  • A management system framework … will be
    introduced as a tool to assist in the delivery and
    systematic management of Responsible Care.
    It should have a built-in capability of certification
    should there be stakeholder reward or a
    business case for doing so.
  • Mandatory self assessment of the
    implementation of Responsible Care by
    companies … will be the minimum baseline
    with a move to periodic verification by
    external parties …
                        Pg. 2
Cefic agreement based on Responsible
Care review (2)
• C2. A Responsible Care Management System
  Framework will be introduced to help companies
  address and manage all the key areas of the
  Responsible Care initiative….based on the Deming
  Cycle of “Plan-Do-Check-Act” and will take into account
  the requirements of existing recognized management
  system standards … and … have an in-built capacity
  to enable it …to be certified …. This course of action
  could be taken as and when a business value is
  identified or when there is potential for stakeholder
  recognition.


                          Pg. 3
Fundamental features of National Responsible Care
programmes and implementing a set of Guiding Principles.
    • Establishing
    • Adopting a title and Responsible Care logo.
    • Implementing management practices through a series
      of systems, codes, policies and guidance documents to
      assist companies to achieve better performance.
    • Developing a set of progressive performance
      indicators.
    • Communicating with interested parties inside and outside the
      membership.
    • Sharing best practices through information networks.
    • Encouraging all association member companies to commit to and
      participate in Responsible Care.
    • Introducing and implementing systematic procedures
      to verify the implementation of the key elements of
      Responsible Care by member companies.
                                Pg. 4
Cefic agreement based on Responsible Care
review (3)
   C3. Verification (implementation assurance) – an
   essential element

 • Verification is considered an essential element of
   the programme …Self-assessment by companies
   on their implementation of Responsible Care is to
   be a mandatory requirement. … there should be
   a commitment to move to periodic external
   assessment.


                        Pg. 5
Self-assessment and Verification
Objectives
 • Company      • Federation
  – drive improvement        – drive industry-wide
                               improvement together
  – assure compliance          with companies
  – address priorities       – share best practices
  – transparency             – address priorities and
  – dialogue                   relevant common issues
  – credibility/             – credibility/acceptance of
    acceptance                 the chemical industry
  – stakeholder              – stakeholder confidence
    confidence
                     Pg. 6
  General information about Responsible Care in Spain

• Responsible Care was adopted by FEIQUE in 1993.

• Not a condition of membership: special Responsible Care budget

• Verification by companies:
  - Implementation of FEIQUE RC Guiding Principles
  - Implementation of FEIQUE RC Codes
  - FEIQUE Responsible Care Indicator Questionnaire

• Verification by FEIQUE:
  - Evaluation of the Guiding Principles Self Assessments
  - Evaluation of the RC Codes Self Assessments



                                                               7
Guiding Principles and Codes for the companies


Responsible Care Guiding Principles: Ten

Content of Codes (revised in 2001):

– Six Codes of Management Practices (Environment, …)
– Management practices and references: Enunciate actions to
  carry on in a generic way.
– References: Specific activities related to each Practice
– Levels: 1 to 6 and n.a.




                                                              8
Self Assessment of Guiding Principles and Codes by
                    companies

 Responsible Care Guiding Principles:
 Self Assessment Questionnaire to be sent out every three years

 Responsible Care Codes:

  – Companies are asked to send the self-evaluation of three codes to
    Feique annually

  – Feique verifies the self-assessment by company visits.
  – Feique identifies opportunities for improvement and gives specific
    recommendations.
  – A final report sent to C.E.O. and RC co-ordinator with general
    recommendations and the results of an internal benchmark.




                                                                         9
     Responsible Care Self - Assessment in Italy

   The FEDERCHIMA RC Self Assessment Questionnaire is a checklist based
    on
        -FEDERCHIMICA “Guide to the Management of the Responsible Care
         Programme” and on
        -Cefic RC SAQ document 1998;
        -further developped in 2001

   FEDERCHIMICA “Guide to the Management of the Responsible Care
    Programme”
        -aims at the diffusion of Integrated Management Systems to
         encourage the development of management systems as an effective
                  approach to manage HSE issues
        -promotes the use of ISO 14001

   Policy for Self Assessment Survey:
         - every 3 years: 1996 and 1999
         -Self Assessment Survey 2002 cancelled for organizational reasons
          (transition to Checklist launched in 2001)
         -new Survey Tool launched in October 2004, presently in progress
                                                                       10
Guide for the Management of Responsible Care Programme


 Guidelines;

 Check List;

 Launched in
2001;
             Detailed for
             each chapter
 Check List
                General
                Summary

                Internal

 Use
                Base for                         11
                Survey
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General Information about Responsible Care in Germany

 VCI adopted Responsible Care in 1991

 Responsible Care is a condition of membership since 1991

 Verification by companies
   • Implementation of VCI Guiding Principles via RC SAQ
   • Implementation of VCI Codes and Guidelines via RC SAQ
   • Continous Performance Improvement via RC IoP Questionnaire

 Verification by VCI
   • Evaluation of the company results
   • Based on the results of VCI„s Self Assessment Survey: priorities and
     areas of activities defined
   • VCI RC workshops for information and experience sharing on demand

Jahr/Vortragsthema/Autor                                                    12
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Guiding Principles and Codes for the Companies



 VCI Responsible Care Guiding Principles based on VCI Environmental
  Guidelines 1986

 Content of VCI Codes/Guidance Documents
   • Environment, Occupational Health and Safety, Transport Safety,
     Process Safety, Product Stewardship, Dialogue/Communication
   • Description of good management practice
   • Levels: 0 (not applicable); I (no), II (implemention planned), III
     (implementation started); IV (yes, implemented), V (implemented,
     checked and integrated in continous improvement processes)




Jahr/Vortragsthema/Autor                                                  13
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Self Assessment of Guiding Principles and Codes/Guidances



 VCI Responsible Care Self Assessment Questionnaire
   • published 1998
   • in line with Cefic RC Self Assessment Questionnaire (1998) for AFEMs
   • based on VCI Implementation Guideline Responsible Care (1995)
   • in revision since 2004




Jahr/Vortragsthema/Autor                                                14
General information about Responsible Care in
               the Netherlands
   VNCI adopted Responsible Care in 1990

   Responsible Care is mandatory for members since 2002

   Verification by companies
      Implementation of VNCI Guiding Principles via RC SAQ
      Implementation of VNCI Responsible Care Codes via RC SAQ
      A yearly environmental report, which is to be validated by the
        authorities
   Verification by VNCI
        Evaluation of the companies RC Self Assessments
        Based on the results priorities for areas of improvement are defined
        VNCI RC Workshops for experience sharing held
Guiding Principles and Codes for
         the companies
 Responsible   Care Guiding Principles based
 on the 12 Cefic guidelines for the
 protection of the environment
 Content   of VNCI RC Codes
     Six Codes of Management Practices
      (Environment, Health, Safety, P.S.
      Transport, Communication)
     Description of good management practice
     Levels: no action (1), inventory phase (2),
      plan (3), do (4), check (5) act (6)
      Self Assessment of Guiding
       Principles and Codes by
              companies
 VNCI    Self Assessment Questionnaire

     Companies are asked to send their self
      evaluation (their self assessment
      questionnaire filled in with the level of
      implementation 1-6) to VNCI annually
     VNCI evaluates the answers to identify
      areas for improvement at sector level
  Dow’s observations on today’s
  programs
• Many commonalities but also many differences

• Federation assessments to date (“first generation”)
  do not reflect company internal systems,
  organization, improvement processes

• Present self-evaluations only partially lead to
  achieving the multiple objectives for self-evaluation
  and verification
                        Pg. 18
Today’s situation with respect to Self-
Assessment and Verification
•   Federation level                             •   Company-level
     – Self-assessment is the main                   – Many sites and installations
       means of verification                           meet ISO or other standard
                                                       requirements (incl. self-
     – Common strengths and                            assessment, auditing and
       opportunities can be identified and
       addressed                                       management system reviews)

     – Difficult to roll-up in aggregated            – These standards are helpful
       industry performance , e.g. to
       support meaningful transparency
                                                     – ISO etc. do not address an
     – draft subsequent SAQ generation                 optimized and balanced
       (tries) to understand, address and              structure in which self-
       assist the performance                          assessment, auditing and
       improvement processes of                        verification on plant, site,
       companies                                       national, and company level are
                                                       put in a common perspective
                                            Pg. 19
     Towards the next generation
     in self-assessment and
•
     verification
    With the Responsible Care Management Framework as the
    reference the multiple objectives for self-evaluation and
    verification, both within companies and within the chemical
    industry, can be achieved through “natural evolution”

• A systematic approach to self-assessment can help to
    – define built-in drivers for continuous improvement in performance,
      relevant for the chemical industry at large and for individual
      companies,
    – apply appropriate differentiation along the value chain and the
      supply chain
    – meet relevant stakeholderPg. 20
                                    expectations in a dynamic manner.
Requirements with respect to self-
assessment and verification
•   Company-level                                  •   Federation level
     – consistent with internal                         – taking into account internal and
       management systems and work                        external expectations
       processes                                        – supportive to address common
     – address full value chain                           improvement opportunities and to help
                                                          enhance company improvement
     – relevant with respect to company                   processes
       specific situations and company
       specific “risks”                                 – relevant for key performance
                                                          indicators
     – include compliance assurance
                                                        – assessment along an agreed
     – drive improvement both in                          framework, recognizing company
       performance and systems which                      diversity
       enable performance
                                                        – avoid unnecessary burden
     – cost-effectiveness
                                                        – dynamic (the “balanced framework
     – dynamic (the “standard” dilemma;                   dilemma”: a common framework with
       global definition/ local                           maximum flexibility)
       implementation/static versus
       change)

                                          Pg. 21
A tiered structure for (self-
)assessment and verification
                                                        company
 •   inspections/ monitoring
 •   self-assessment
 •   internal auditing
 •   external auditing
 •   management system and performance review
 •   other (complementary and/ or statistical)
     verification

 > geared to individual company specifities and needs
 > aligning with overall industry continuous
   improvement in systems and performance             federation
                           Pg. 22
                                  Leadership & Commitment                               Continual improvement :
                                                                                        •System
                                           Policy
                                                                                        •Key Industry
external verification
                                                         Identify Requirements          Performance Indicators
                Management                                                                  •Occupational Health &
                  Review                                            Set Objectives,         Safety
                                                                   Targets and Plan
                                                                                            •Process Safety
                                   ACT          PLAN              Define Organisation       •Environment
                                                                                            •Product Stewardship
                                  CHECK             DO
                                                                                            •Distribution
                                                            Implement and put               •Emergency
                        Monitor                              controls in place              Preparedness
 inspections/
 monitoring
 self-assessment
                                                                                        •Key company
 internal auditing
 external auditing
                                                                                        performance indicators

                                    Continual improvement
                                                                                        •Stakeholder Engagement
                                                                                        •Outside-in perspectives
                                                         Pg. 23
    Path forward (multi-generation
    approach)      2       3    1  4

•   framework           broad definition/ main                               guidelines for
                        elements                  add next level of detail                          assess value and need
                                                       to main elements      implementing main      for next generation
                                                                             elements               framework/ standard


                                                  •    guideline for         pilot SAQ2             implement SAQ 2
•   federations   •     assess best practices
                        for self assessments           management
                        and management                 reviews
                        reviews
                  •     guideline for company     •    assess
                        self-assessment                implementation of
                                                       SA and MSR
                                                  •    SAQ 2 draft1

•   companies
                      integrate self-assessment                              pilot external party   •implement external party
                         in management system                                verification
                                                  integrate management                              verification
                                                        review in                                   •apply selective 3rd party
                                                        management                                  verification
                                                        system
                                                  define and implement
                                                        verification
                                                        structure
                                                       Pg. 24