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

                          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
    • Communicating with interested parties inside and outside the
    • 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

                        Pg. 5
Self-assessment and Verification
 • 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
                     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

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.

Self Assessment of Guiding Principles and Codes by

 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
  – A final report sent to C.E.O. and RC co-ordinator with general
    recommendations and the results of an internal benchmark.

     Responsible Care Self - Assessment in Italy

   The FEDERCHIMA RC Self Assessment Questionnaire is a checklist based
        -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
        -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
Guide for the Management of Responsible Care Programme

 Guidelines;

 Check List;

 Launched in
             Detailed for
             each chapter
 Check List


                Base for                         11
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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
   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
 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
• 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
    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
    – 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
     – 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

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

 > geared to individual company specifities and needs
 > aligning with overall industry continuous
   improvement in systems and performance             federation
                           Pg. 22
                                  Leadership & Commitment                               Continual improvement :
                                                                                        •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
                                                            Implement and put               •Emergency
                        Monitor                              controls in place              Preparedness
                                                                                        •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
                  •     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
                                                  define and implement
                                                       Pg. 24