RESPONSIBLE CARE® - Chemistry Industry Association of Canada

RESPONSIBLE CARE®
Verification Report
Honeywell ASCa Inc
November 22 - 23, 2010
Disclaimer
This report has been produced by a team, convened by the Chemistry Industry Association of
Canada (CIAC), to provide advice to the member-company and assist it in meeting its
Responsible Care® commitments. The material in this report reflects the team's best judgment in
light of the information available to it at the time of preparation. It is the responsibility of the
CIAC member-company that is the subject of this report to interpret and act on the report’s
findings and recommendations as it sees fit. Any use which a third party makes of this document,
or any reliance on the document or decisions made based upon it, are the responsibility of such
third parties. Although CIAC members are expected to share the results of this guidance
document with interested parties, the Association, its member-companies, their employees,
consultants and other participants involved in preparing the document accept no responsibility
whatsoever for damages, if any, suffered by a third party as a result of decisions made or actions
based on this report.
Responsible Care® is a registered trademark of the Chemistry Industry Association of
Canada.
EXECUTIVE SUMMARY AND TEAM CONCLUSIONS
nd
rd
On November 22 and 23 2010 a verification team representing the Chemistry Industry Association
of Canada conducted a Responsible Care® re-verification of the Honeywell ASCa Amherstburg plant
utilizing the CIAC 2009 re-verification protocol. The team was comprised of three verifiers selected by
the Association and one verifier selected by the local Amherstburg community through the site’s
Community Advisory Panel (CAP).
The team gathered information by reviewing the pre-visit information package provided by the
company, reviewing documentation on the site intranet and interviewing managers and employees at
the site. The team also met with the CAP separately for discussions about the Company’s community
dialogue and interaction with the community in general. The Amherstburg fire chief and police chief
are permanent members of the CAP. As a result of this process there is a team consensus that the
Honeywell Amherstburg site has completed their 2010 Responsible Care® re-verification.
While the Responsible Care® Ethic is evident at the site a further strengthening of the Ethic would be
desirable as evidenced by a perceived disconnect between management and the hourly employees
in support of site safety management systems and staffing levels.
The following report lists one finding requiring action in the application of the management system
functions of “planning” and “doing” to identified findings requiring action from the 2007 report and
twelve improvement opportunities in the areas of the Responsible Care® management system,
utilizing performance measures, process safety management, emergency response, Responsible
Care® visibility and risk communications.
The report also identifies two industry best practices in the areas of process safety management
and community dialogue.
The team would like to thank Honeywell for their cooperation and hospitality during our visit. The
team would also like to acknowledge the transparency and robustness of the company’s Responsible
Care® Management System that allowed the rev-verification to proceed in spite of a very recent
serious process incident. In response to that incident all site emergency response systems
responded as planned.
For more information on this or a previous re-verification or on the company’s original report for
verification of Responsible Care®-in-Place, please contact your local company site or the company’s
overall Responsible Care® coordinator:
Giovanni Grande, Tel: 519-730-2035, [email protected]
Cameron Dillabough,
Re-verification Team Leader
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1.
INTRODUCTION AND OVERVIEW
1a)
The company
This is the report by the verification team on those operations of Honeywell ASCa Incorporated which
are covered by the company’s commitment to the Responsible Care® initiative of the Chemistry
Industry Association of Canada description of the company in Canada and which operations are
covered by this report can be found in Appendix 1.
1b)
Responsible Care®
Responsible Care® is an initiative of the Chemistry Industry Association of Canada (CIAC) by which
the association’s members and partners commit to be, and to be seen as, responsible companies
within Canadian society. It is based on an ethical approach to the safe and environmentally sound
management of chemicals – an approach which started in Canada but has since spread to over 45
countries around the world.
The Responsible Care® Ethic:
We are committed to do the right thing and be seen to do the right thing.
We are guided towards environmental, societal, and economic sustainability by the following
principles:
 We are stewards of our products and services during their life cycles in order to
protect people and the environment.
 We are accountable to the public, who have the right to understand the risks and
benefits of what we do and to have their input heard.
 We respect all people.
 We work together to improve continuously.
 We work for effective laws and standards, and will meet or exceed them in letter
and spirit.
 We inspire others to commit themselves to the principles of Responsible Care®.
The ethic is supported in Canada by six codes of practice covering relations with the communities
where members’ facilities are located and also responsible management throughout the product life
cycle. Information on these codes of practice and related activities is available from company
personnel listed in Appendix 2 of this report, or via the CIAC web site www.canadianchemistry.ca
(click on the tab for Responsible Care®).
1c)
Expectations of CIAC members and partners
Each CIAC member or partner company must formally commit to the ethic, principles and codes of
practice of Responsible Care® as a condition of membership in the association.
Progress in implementing these obligations must then be reported to CIAC, both to peers at special
networking meetings and also via a formal reporting system to the association. Three years is the
typical time allowed to new members for implementation. The association monitors progress and
follows up by arranging for assistance where necessary to ensure that each company eventually
meets its commitment.
When a company considers that its management processes are sufficiently comprehensive that they
meet each of the 151 individual code requirements, it advises the association that implementation is
complete to the stage of “Responsible Care®-in-Place”. Completion in this sense does not imply that
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nothing further needs to be done, but that a key milestone has been reached in a process of
continuous improvement.
1d)
Verification
A company’s declaration that the expectations of Responsible Care® are being met is an important
first step in the verification process, which leads to confirmation and recognition of this by a team of
industry and public representatives. Verification is conducted to strict protocols, developed by the
association’s members and others including several critics of the chemical industry and its
operations. The first verification takes place when the company first states that its performance
meets the expected level (Responsible Care®-in-Place). This verification is designed to confirm, for
the company’s peers in CIAC and the public, the existence of a company wide ethic and
management systems which ensure that the principles and codes of practice of Responsible Care®
are not only in place but are also practised and continuously improved within the organization.
Subsequent verifications are also conducted using a different protocol, approximately every three
years after formal acceptance of the first verification, to ensure that the ethic and management
systems of Responsible Care® are firmly rooted in all the company’s operations. This is known as reverification.
Each verification is conducted by a team consisting of:
 knowledgeable industry experts with experience in Responsible Care®;
 a representative of the public at large (usually with a public interest background and with
experience in Responsible Care® gained from serving on the CIAC national advisory panel)
and
 one or more representatives of the local communities where the company’s facilities are
located.
1d)
i) Verification of Responsible Care®-in-Place
For the purposes of this examination, a portion of the 151 code requirements is sampled in depth.
These items are grouped into seventeen management systems, each of which is examined using a
series of questions. Some of the questions are sent to the company in advance of the verification
visit, so that supporting documentation, etc. can be available for prompt examination if desired.
Additional questions are asked at the discretion of the team during the visit.
The approach is “top-down” rather than the “bottom-up” used in conventional audits, and the style of
questions is intentionally open-ended, so that the answer cannot be a simple yes/no but calls for
explanation. The questioning process starts with the executive responsible for chemical operations
in Canada, and works down through the organization to examine the senior level intent and the
corresponding support by action at the operating level.
Responsible Care®-in-Place verification of Honeywell ASCa Inc.
Company name at time: Honeywell ASCa Inc.
Date of verification (visit): November 1st & 2nd 2007
Locations visited: Amherstburg ON
Team follow-up needed: Yes
th
Date of final sign-off: April 29 2008
Please note: Due to a gap in the continuous operation of the Amherstburg facility the November
2007 re-verification included a review of Responsible Care® in-place verification requirements. The
2007 reverification report will serve as both the in-place and first re-verification report.
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1d)
ii) Re-verification
Approximately every three years after team acceptance of Responsible Care®-in-Place, the CIAC
schedules further verifications using a modified approach. The team is similar to that for the original
verification, with at least one team member from the previous verification but a different leader.
In re-verification the team probes more deeply to examine how well the ethical basis of Responsible
Care® is understood and adopted within the company, and also how effective are the company’s
management systems in applying the ethical principles throughout the company’s operations. This
involves not only whether the company intends to do the right things, but also how it monitors
activities and results and takes corrective action when deviations occur (often referred to as the PlanDo-Check-Act parts of the management system).
For re-verification the company is given a more comprehensive list of documentation the team will
need to see. Part of this must be sent to the team so they can study it in advance. The questioning
process is also more open, in that the team does not have to cover every topic in depth but can
probe where they feel it is most relevant for that individual company, plus any areas where the
company itself would like feedback on its performance.
After studying the information the team meets with the company to plan the visit stage of the
verification, at which a schedule is agreed covering people the team wishes to interview in depth
during the subsequent visit stage of the verification process. Most of these will be company
personnel, but some will be representatives of organizations with which the company has business
relationships – customers, transporters, etc. – and of local communities where plants, etc. are
located.
The team examines to determine how strongly the Responsible Care® ethic appears to be part of the
company’s way of doing business, including awareness of Responsible Care® and its implications
among the company’s employees. The examination then progresses into a broad-ranging review of
the company’s management systems for Responsible Care®, with a special investigation into certain
topics highlighted by CIAC in the verification protocol.
The team looks at how effectively the company’s management systems ensure that Responsible
Care® principles and code obligations continue to be met, as established in the initial Responsible
Care®-in-place verification. In subsequent verifications, however, the questioning process also
considers how the company tracks and improves its performance regarding these obligations,
including how performance measures are established and targets met (what is measured, what are
the goals and how are they achieved). Actions taken on concerns, suggestions and
recommendations raised in the last verification report are examined, as are significant issues and
incidents that have arisen since the previous verification. The team then looks at how the company
shared the results of this verification with the local community, and examines how robust the ongoing
process of community dialogue appears to be and how issues and concerns are being identified and
addressed.
The highlighted topics of special focus are ones where the feedback from the verification process
and from the association's members has suggested the value of a closer examination of the general
membership performance and comparison with the intent of the codes of practice. This does not
necessarily imply that any given company is not performing well, but reveals the range of
performance and identifies both cases where some improvement is recommended and also
examples from which others can learn.
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The highlighted topics include community dialogue, process safety management, site emergency
preparedness and response, security regarding malicious threats that could impact public safety or
well-being, health effects of products and plant emissions, product stewardship and “TransCAER”
outreach. Also examined are emissions of greenhouse gases, and how companies with emissions of
volatile organic compounds are meeting the intent of a CIAC agreement on this topic with the federal
and provincial governments and environmental groups. Although CIAC. has no defined performance
expectations for broader social responsibility, the team also looks at how the company sees and
fulfills its role in this area. The team may also comment on other specific topics where the company
has requested feedback.
The report below presents the findings of the team from this re-verification of Honeywell ASCa Inc.
The report does not address all aspects of Responsible Care®, as this was covered by the report of
the original Responsible Care®-in-Place verification. Instead, it focuses more on the items where the
team felt there was an opportunity or need for improvement, plus any improvements or practices
which are so significant that they should be shared with other CIAC members and partners as
possible examples.
For more context or explanation of any of the items below, please get in touch with the contact at the
company from whom you accessed this report.
In the following sections of this report, findings requiring action are shown in bold face,
opportunities for improvement (recommended but not considered mandatory) are shown in italics,
while “extra miles” and best practices are shown underlined).
2.
GENERAL FINDINGS OF THE TEAM
2a)
Statement on the Responsible Care® Ethic
Throughout the interview process the team checked for evidence that the Responsible Care® ethic
was visible and at work in the company, guiding the company’s judgement, decisions and actions.
Team Findings
Responsible Care® is an integral part of the operational philosophy of the Amherstburg plant and the
transparency of the Responsible Care® management system was demonstrated by the company
electing to continue with the verification team visit in the wake of a major process incident. The
Responsible Care® Ethic, for the most part, is understood and guides the day to day activities of the
site but there is an opportunity for improvement for further understanding and strengthening the Ethic
as evidenced by a perceived disconnect between the hourly employees and management in the
application and support of the site safety programs and staffing levels. An indicator in support of this
perception is a relatively poorer safety performance of the site compared to their CIAC peer
companies. The improvement opportunities will be listed in the appropriate sections of the report.
2b)
Overall Responsible Care® Management System
It is a requirement of Responsible Care® that companies have documented, sound management
systems capable of ensuring that all operations of the company across all business units, functions
and sites meet the ethic, codes of practice and other expectations of Responsible Care® on an
ongoing basis. A sound management system drives continuous improvement, and has the following
attributes:
Plan - review code requirements
- benchmark best practices
- get input from stakeholders
- decide on best approach
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- set targets for performance
- assign responsibility
Do
- document
- train people
- assign resources
- carry out activities
Check- audit
- measure performance of system
- measure performance from system
- obtain stakeholders’ feedback
- assess employees’ performance
Act
- follow-up on audit findings
- communicate performance, get feedback
- reward or correct employees
- repeat Plan steps
There must be such management systems both for the overall management of the company and for
each code element. This section 2.3 covers the team’s findings with respect to this overall
management system, and section 3 below covers the specific code elements that were reviewed in
the re-verification.
Team Findings
As an overriding document the company has developed a cross reference document that
demonstrates how each corporate and site standard and procedure applies to the original 151
Responsible Care® code elements. This document can also be utilized as a reference document for
the annual internal pre attestation Responsible Care® audit. It is the expectation that this document
will be the basis for a gap analysis to determine what additional policies and procedures might be
required to support the revised Responsible Care® Commitments.
Planning is accomplished through a series of annual goal setting processes that begin with corporate
global objectives and goals and supportive cascading goals through the Specialty Materials Division
to the Canadian entity. Goals and objectives can be the result of a corporate vision, legislative
requirements, internal and external audits and benchmarking against other companies and various
industry association members.
Doing is accomplished through the development of group and individual key performance indicators
(KPI) which are actions in support of the goals of the organization.
The checking process for the management system is completed through a comprehensive internal
and external audit process that monitors performance on a frequency as varied as weekly to tri
annually as in the case of this Responsible Care® re-verification. Individual KPIs are monitored by
individual group or department managers.
The Amherstburg site utilizes corrective action tracking system to list all audit and verification
findings. This tracking system includes managerial responsibility and target completion dates.
As part of the “checking” process the Amherstburg site has estimated that approximately 15% of the
Corporate Responsible Care Management System, (RCMS) which applies to the site, does not
adequately address CIAC Responsible Care® requirements.
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There is an opportunity for improvement to complete the gap analysis and cross reference process to
determine what areas of the RCMS need to be bolstered by additional procedures to attain
compliance with CIAC requirements.
There is an opportunity for improvement to notify the Specialty Materials Corporate entity that
procurement policies 1.6.51, 2.4.1, 2.9.2 and Transportation and logistics policy 5.2, submitted for
the verification, have not been reviewed since 2005.
2c)
Follow-up on Findings in Last Verification Report
The team reviewed how the company addressed the findings requiring action and opportunities for
improvement cited by the previous verification team in their report to the company. Certain follow-up
items are covered in the specific topics below.
Team Findings
The 2007 re-verification report noted twenty findings requiring action. Two findings were not fully
addressed by the Responsible Care® management system. The first related to Product Stewardship
and the requirement for a management system to effectively implement, collect, analyze and address
customer and supplier self assessments. The second related to a management system to select and
assess motor carriers that haul raw materials and waste on the company’s behalf.
It is a finding requiring action to fully address the two findings, noted above, from the 2007
report. Those findings required:
The company to develop a management system to ensure supplier self assessments are
completed and returned by suppliers, considered by the company when choosing suppliers
and to define a supplier assessment review frequency.
The company to develop a management system to ensure Responsible Care® related services
provided at the corporate level conform with the site’s Responsible Care® commitments.
The company to establish carrier selection criteria for haulers of raw materials and site wastes
based on the established risk criteria for the raw materials, waste and mode of transport.
2d)
Response to Incidents and Concerns since the last Verification
Since the way in which unplanned situations are handled shows the influence of the Responsible
Care® ethic and responsiveness of the management system, the team looked at the issues,
incidents and concerns that have arisen since the last verification and how the company has handled
them. Some of these may be covered under individual topics below, as noted.
Team Findings
There is in place a comprehensive management system, based on the standard operating procedure
SOP-HSE-034, that fully complies with expectations of Responsible Care® in the area of response
to, and management of incidents.
Just prior to the verification visit there was a major site incident that was reviewed with verification
team. The response and management of the incident demonstrated the robustness of SOP-HSE-034
and the supporting corporate level incident investigation and management systems.
2e)
Performance measures
The ‘check’ step of a management system is the part that shows the effectiveness of the system,
and a key question is: “What does the company check as its indicator of performance?” For a few
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items – emissions & wastes, occupational safety & health, incidents related to transportation or
process operations – CIAC specifies measures for reporting under Responsible Care®. Most other
areas are left to the discretion of each member or partner. The team was asked to review and
comment on the measures used by the company to track and improve performance. Some of these
are covered under specific sections below, but general comments are given here.
Team Findings
The site has an excellent process for collecting data on the fifteen site related metrics plus the four
CIAC mandated metrics relating to emissions, transportation incidents, employee and contractor
accidents and process related incidents. Trending data analysis is performed on employee accidents.
In addition there are corporate sustainability metrics and annual site focus metrics that are generated
to support corporate improvement goals. Benchmarking tends to be against similar Specialty
Materials facilities within the company and not their CIAC peers. There is a gap in the “checking” and
“acting” functions of the metric management system and there does not appear to be a link between
all data collection points and the annual improvement goals particularly the metrics specified by the
CIAC
There is an opportunity for improvement to utilize the site SHARE related Total Recordable Incident
Rate data to benchmark and improve the sites employee safety performance. (SHARE is an acronym
for a CIAC sponsored Safety & Health Analysis Recognition and Exchange)
There is an opportunity for improvement to more clearly link the site metrics to annual improvement
goals particularly the CIAC specified performance measures.
In addition to examining how the company has performed in the four priority topic areas, the
team also looked into some additional selective areas of focus, as noted below.
3.
TEAM FINDINGS FOR SPECIFIC CODE MANAGEMENT SYSTEMS
In examining how the company is fulfilling the specific expectations of Responsible Care®, the team
focused first on four topic areas identified as priority items by the CIAC board of directors for the
period 2005-2008. These are process safety management and the related site emergency response,
product stewardship and environmental management.
3a)
Process safety management (PSM)
The team looked at how the hazards and risks from potential episodic ('sudden') incidents are
identified and controlled at the company’s sites, including awareness and understanding of the
methods used for assessment and the techniques for hazard control, and how these are applied and
kept current. This includes how the company’s sites rank based on the Site Self-Assessment Tool of
the Chemical Institute of Canada – whether they meet criteria for the “essential” level of PSM, and
how the company has assessed the value of aspects beyond the essential level.
Team Findings
As previously described the Amherstburg location is part of the Honeywell Specialty Materials
Division and subject to the Corporate PSM management system. In turn, because of the level of risk
involved, the site is subject to the U.S. Occupational Safety and Health Administration’s rigorous
PSM criteria which fully meets the expectations of Responsible Care®. Based on the CIAC PSM self
assessment criteria the site is at the enhanced level.
There is a Corporate initiative entitled the Honeywell Operating System which is an integrated
management system based on a quality improvement “six sigma” foundation that drives sustainable
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safety, quality, delivery, cost and inventory improvements. This system focuses on standardized
work, rapid problem solving continuous improvement and knowledge sharing.
In addition there is a Specialty Materials Division initiative for safety improvement called the
Structured Safety Process which is designed to engage all employees in safety improvement. The
premise is to utilize a system of one-on-one discussions with employees to ensure documented
policies and procedures are followed or initiate improvements to make the policies and procedures
more relevant.
The team judges the Honeywell Operating System and the Structured Safety Process to be industry
Best Practices
There is an opportunity for improvement to leverage the knowledge gleaned from the documentation
of emergency response procedure training/retraining and apply this knowledge to the development of
a process for all plant job functions.
3b)
Site Security & Emergency Response
The team looked at how the company had identified and assessed the security vulnerability of its
sites, and how it had selected and implemented countermeasures to address security concerns. The
team also examined how the company assesses the full range of risks its site operations may
present to their communities, together with the process for liaison with local emergency officials at
each site, and for developing, coordinating and testing site emergency plans with those of the
community.
Team Findings
The Amherstburg site has completed the required site vulnerability assessment and has addressed
the identified improvement areas. One action item is complete and the other is pending funding
approval.
Based on the site risk profile there is a very comprehensive emergency response plan in place.
There is appropriate interface with the Local Emergency planning Committee (LEPC) including an
integration of the site plan with the LEPC plan. A process of annual testing and critique and periodic
training of site responders is utilized to keep the plan current and focused. Both the Amherstburg Fire
Chief and Police Chief are members of the site’s Community Advisory Panel.
There is an opportunity for improvement to document the process now used to determine the
frequency, content and expected outcomes of training for site emergency responders.
There is an opportunity for improvement to assess and document the training frequency for
Honeywell and third party security personnel that might be involved in emergency situations, such as
bomb threats and suspicious packages that originate outside the site perimeter.
3c)
Product Stewardship
For this aspect of Responsible Care®, the team examined the company’s processes for:
i) assessing the exposures of people to its products over their life cycles, assessing the
potential health implications of these exposures, communicating information to those potentially
affected and taking action to prevent health impacts;
ii) ensuring that their products are not used by terrorists, the illegal drug industry or others who
might use them for illegal purposes; and
iii) ensuring that suppliers of chemicals are meeting the intent of Responsible Care®.
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Team Findings
The corporate product stewardship philosophy is supported by their membership in the International
Council of Chemical Associations which has as a goal the harmonizing of global product safety
assessments through the Global product Strategy. As a result the corporation has developed a
comprehensive product stewardship management system for the production, sale and distribution of
hydrogen fluoride which is manufactured at the Amherstburg site. Elements of the management
system include focused safe work practices and employee training, dedicated rail and highway
shipping modes, technical training and over site of customers and Specialty Materials Assessment of
Risk Teams.
3d)
Environmental Management
In addition to examining in general the company’s performance in reducing its environmental
“footprint, the team looked specifically at the company's performance history and 5-year projections
regarding greenhouse gas emissions. This included actions both taken and planned and whether
through direct reduction of emissions or indirect reduction through such measures as improved
efficiency in use of energy or materials, changes in technology, etc.
For fact-finding purposes only, to assist CIAC in developing recommendations for addressing
growing concerns over water consumption, the team also reviewed any actions taken by the
company to identify and reduce its usage of water.
Team Findings
As part of to the corporate commitment to Responsible Care®, Environmental Stewardship is an all
encompassing goal for the Specialty Materials Division. That goal results in standards and policies
that promote sound environmental management systems that range from process safety
management to product stewardship and a focus on reducing the environmental footprint of
manufacturing facilities. At the Amherstburg facility goal in support of the corporate initiative are
identified as Sustainability Metrics and range from hazardous waste generation to water quality and
greenhouse gas emissions. Projects to improve the sustainability metrics have focused on energy
reduction and efficiency and first pass quality.
3e)
Visibility & Employee Awareness of Responsible Care®
Here the team looked at how the company seeks to make Responsible Care® a visible part of its
facilities and its internal and external communications, and how it ensures that all employees
understand the essence of Responsible Care® and its relevance to their job activities and decisions.
Team Findings
The corporate Specialty Materials Division is a signatory to the Responsible Care® Global Charter
and is a member of the American Chemistry Council. The goal of the division is to support
Responsible Care in the countries in which it conducts business operations. In support of this goal
the Amherstburg site has integrated Responsible Care® by name, into its annual goal setting
process, site documentation, managerial annual performance objectives and communications with
the public.
There is an opportunity for improvement to amend the description of the Executive Contact’s
responsibilities to reflect the expectations of an Executive Contact of a CIAC member company and
an in- country representative of the parent corporation.
3f)
Workplace Health & Safety
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The team looked at the company’s processes for continuous improvement in protecting the safety
and health of employees, contractors and visitors.
Team Findings
The corporate Specialty Materials Division has a comprehensive management system to address the
need for workplace health and safety. The Amherstburg site in turn is responsible for applying these
safety management system components to their day to day operations. The overall corporate annual
target for safety, health and the environment is “zero incidents”. To support this target the
Amherstburg site develops annual improvement objectives as part of the planning process of safety
improvement. The doing or application of processes and programs is evidenced by: robust
operational procedures, including “life critical” procedures, process hazard analysis on a continuous
basis, incident reporting, management of change procedures and behaviour based safety audits.
The checking and acting processes are supported by external corporate audits, external third party
audits, internal audits and Joint Health and Safety Committee workplace inspections. Corrective
actions from the inspection and auditing processes are tracked to completion on the site corrective
action data base.
The corporate incident tracking system has identified a trend in injuries that can be attributed to
ergonomic factors in job performance and has implemented an analysis of ergonomic factors in the
performance of site job activities.
A comparison of the site’s safety performance against other CIAC member companies in their
reporting group shows the site has the second highest overall incident rate.
Based on a limited number of hourly employee interviews the team sensed that there is a disconnect,
possibly attributed to other operational factors, between the site hourly employees and the
management of site safety initiatives.
There is an opportunity for improvement to address any operational factors that prevent the total
support by workers of the site’s safety management systems.
3g)
Site Risk Communications
The team looked at the company’s management system for ongoing communication and dialogue on
the risks of its site operations with potentially affected communities.
Team Findings
The corporate Speciality Materials procedure SMHSE731 directs the required risk communication
bases on the relative risk of the Amherstburg facility. To comply with the Canadian Responsible
Care® commitment the facility has included instructions, in a community brochure, on how the
affected community should respond to a site worst creditable event scenario. The site is also a
member of the Local Emergency planning Committee and regularly holds on- site training for
members of the local emergency response agencies. In addition the site nurse annually provides
refresher training in responding to hydrofluoric acid injuries for local hospital emergency room
employees and upgrades the specific hydrofluoric acid first aid kits.
There is an opportunity for improvement to amend SPO-RC-01 to require an annual spot check of
people, living and working in the worst case scenario impingement area, remember what action to
take in the case of an on-site event.
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There is an opportunity for improvement to assess what specific risk communication might be
required for the local golf club and special event facility, the marina and any other group community
activities.
3h)
Dialogue process with communities
The team looked at how the company’s broader process for dialogue with its communities has been
working since the previous verification, including the identification of stakeholders, community issues
and concerns, how concerns were addressed and the choice of dialogue methods. They looked at
the effectiveness of the management system in ensuring the company is planning, implementing,
evaluating and continuously improving its relationship with the community.
Team Findings
There is a comprehensive Responsible Care® management system in place for community dialogue
based on the corporate procedure SMHSE731 that directs a site’s community dialogue process
based on the risk level of that site. This procedure is in turn supported by Honeywell ASCa
procedures SOP-RC-001 & 002 that addresses the specific needs of the Amherstburg site. In
accordance with these procedures an informational brochure was distributed to the community in
September 2010 and a general community meeting was held in November of 2010. Community
Advisory Panel meetings are also being held on a regular frequency.
The team judges the 2010 community information brochure as an industry best practice.
There is an opportunity for improvement to apply a Self Assessment (SAT) audit to the site
community dialogue process ,including risk communication, as an method of further support to the
annual Responsible Care® attestation process.
3i)
Social Responsibility
In this area the team was not looking for evidence that the company's performance met certain
expectations, but rather for information on ways the company has provided benefits to, and worked
to understand and further the social aspirations of, its local communities and broader society beyond
the boundaries of EH&S performance. Aspects considered include working with schools,
progressive employee programs, support for charitable work, policies for investments and operations
abroad, workplace diversity, corporate ethics policies, policies for suppliers in social responsibility,
etc.
Team Findings
Through Hometown Solutions, a corporate Honeywell International outreach process, Amherstburg
focuses its community involvement and corporate giving on three specific areas: science and math
education, family safety and security, and housing and shelter. Some examples include; local
donation of fire fighting safety equipment, donation of a breathing air compressor to local fire
department, a toy and canned food drive at Christmas for the local food bank, sponsoring Sparky’s
participation in local fundraising committees and participation in Detroit River Cleanup Committee.
3j)
Engagement with Elected Officials
Since part of Responsible Care® is a commitment to assist in the processes of sound public policy
development consistent with the criteria for sustainable development, the team reviewed the
company’s process for establishing ongoing relationships with elected officials (i.e., MPs, MPPs, city
councillors, etc.) in constituencies where the company has a presence, to acquaint those officials
with the nature of the company’s operations, economic impact, Responsible Care® commitment,
activities and public policy concerns, and to understand the elected officials’ interests and concerns.
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Also reviewed were the company’s engagement in CIAC activities aimed at assisting in the
development of sound public policy (e.g., Parliamentary Day, policy discussions, lobbying, etc.).
Team Findings
The primary focus of the Company in this area is with developing and maintaining a relationship with
local politicians. A Town Councillor attends the CAP meetings and the facility has a historical
relationship with the Village mayor. It has been the company practice to attend the annual CIAC
parliament day.
3k)
Transportation Security
The team looked at how the company assesses the risk of deliberate misuse of products or raw
materials in transit and provides protection against such risks.
Team Findings
Transportation security is a component of the Specialty Materials Safety Management level two
standard. All Responsible Care® transportation security expectations are met by this standard and
the Amherstburg Materials Handling Emergency Response Assistance Plan.
3l)
Carrier Selection
The team looked at the company’s process for establishing criteria for the selection of road, rail,
marine, pipeline and air carriers, and for ongoing assessment of those carriers against those criteria.
Team Findings
Finished product from the Amherstburg site and similar products delivered from Honeywell sites in
the United States by roadway is shipped via the Company’s private truck fleet that is subject to
comprehensive transportation focused safety management system. Other carriers used by the
Amherstburg facility or the Specialty Materials Division are subject to the Specialty Materials
Standard SMHSE610. For the purpose of verification records of motor carrier evaluations for the site
waste haulers could not be located. (reference the finding in section 2C)
3m)
TransCAER Outreach
TransCAER is the CIAC program for Transportation Community Awareness and Emergency
Response. It involves the company’s approach to preventing transportation incidents, its
transportation emergency response plan, and also outreach to communities through which chemicals
are transported. Company responsibilities are decided by regional TransCAER committees formed
from the members and partners in each region. The team looked at how the company has
participated in TransCAER outreach in each region where it has facilities, and how effectively the
Responsible Care® ethic drives the building of relationships with targeted stakeholder groups.
Team Findings
The Amherstburg site is an active member of the Local Emergency Planning Committee and as such
participates in and sponsors emergency drills both at their plant site and in the surrounding
community. The Company also supplies a mock tanker trailer and instructors to train customer
emergency response personnel at the customer’s manufacturing sites.
Involvement in CIAC sponsored TransCAER sector meetings has been sparse in recent months due
to personnel changes. The Company has identified this weakness and are taking steps to increase
attendance at sector meetings.
The plan to increase attendance at TransCAER sector meetings is viewed as a “work in
progress” and should be a focus area for the next re-verification.
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3n)
Areas of Focus Requested by the Company
In addition, the company asked the team to investigate the following aspects of Responsible Care®.
There were not any specific focused aspects of Responsible Care® requested by the Company.
3p)
Additional Areas Addressed during the Re-verification
The Company was verified using the CIAC 2009 protocol. In addition the team completed a fact
finding exercise to determine what progress the Company had made in assessing their contribution
to the CIAC Principles of Sustainability and completing an implementation gap analysis of 2010
Responsible Care® Commitments. The results of this analysis are shown in appendix # 3.
4.
CONCLUSION
It is the consensus of the CIAC re-verification team that Honeywell ASCa has been re-verified as
meeting the requirements of Responsible Care®, will continue to build on its strengths, and address
any finding or improvement opportunities in a timely manner.
5.
COMPANY COMMENTS
On behalf of the site and HSE Team, we would like to express our sincere appreciation to the
verification team and the CIAC for all its hard work and direction in helping Honeywell maintain the
high standards established through the Responsible Care® Ethic
APPENDIX 1
COMPANY DESCRIPTION
The Honeywell ASCa Inc. facility is located on the site of the former General Chemicals facility in
Amherstburg ON. This facility manufactures hydrofluoric acid that is utilized as a feedstock in the
manufacture of fluorocarbons and fluoropolymers. These chemical derivatives are used by industries
as diverse as nuclear fuel production and the manufacture of stainless steel and titanium.
The Amherstburg facility is part of the Honeywell Specialty Materials division which is in turn part of
Honeywell International. Hydrofluoric acid from the Amherstburg facility is shipped to customers
throughout North America.
For additional information visit the Honeywell International website and access “Specialty Materials.”
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APPENDIX 2:
RE-VERIFICATION TEAM AND COMPANY CONTACTS
1.
The Verification Team
The verification team consisted of the following:
Name
Affiliation
Representing
Cameron Dillabough
CIAC Verifier
Industry (team leader)*
Gerry Whitcombe
CIAC Verifier
Industry*
Kris Lee
Community at Large Verifier Public*
Aline Hilton
Local Community verifier
Amherstburg Community
Team members assigned by CIAC are shown by an asterisk (*).
2.
Persons contacted at the company
Name
Position
Vaughn Hansen
Plant Manager
Giovanni Grande
HS&E manager and overall Responsible Care® Coordinator.
Kelly Ludberg
Environmental Engineer, Responsible Care® Coordinator.
Rod Shaw
Technical Manager.
Rick Mamak
Plant Nurse
Peter Smeltzer
Supply Chain (Logistics).
Randy Johnson
Joint Health & Safety Co-Chair.
Joseph Capaldi
Laboratory Analyst – Office and Technical Representative.
Don Carter
Transportation.
John Blyton
Safety Technician and Joint Health & Safety worker
Representative.
Lois Martin
Community Advisory Panel (CAP) Member.
Lynwood Martin
CAP Member.
Rick Murray
CAP Member, Amherstburg Fire Chief.
Tim Berthiaume
CAP Member, Amherstburg Police Chief.
Mike Cox
CAP Member, Amherstburg Police Sergeant.
Witness Mpesha
CAP Member
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APPENDIX 3:
The Responsible Care Ethic and Principles of Sustainability

Work for the improvement of people’s lives and the environment, while striving to do no harm.
 Honeywell has a number of projects geared to the protection of the environment and
energy conservation while improving conditions for people
 Environmentally friendly refrigerant development & commercialization
 Safety products
 Energy conserving insulating product
 Spectra fiber
 Low-global-warming-potential blowing agents
 Non-ozone depleting hydrofluorocarbons

Be accountable and responsive to the public, especially our local communities, who have the
right to understand the risks and benefits of what we do
 Honeywell Specialty Materials defines the requirements for communications with local
communities and emergency responders to ensure accountability and responsiveness
 Public Right-to-Know meeting held November 2010 for local residents (to be
annual)
 Community newsletter issued (quarterly)
 Active Community Advisory Panel (quarterly meetings)
 Residential Communications process

Take preventive action to protect health and the environment
 Honeywell follows the US PSM regulation
 Conduct Process Hazard Analysis
 Management of Change process
 Employee training
 Mechanical Integrity
 Job hazard analysis (for workers)
 Risk management for new product development

Innovate for safer products and processes that conserve resources and provide enhanced
value
 Product Stewardship program well developed along with SMART team for product
development
 Modified HF product (reduced fuming)
 Low-global-warming-potential blowing agents
 Low-global-warming-potential refrigerants
 Electronic materials products for increased efficiencies in solar panel cells
 UOP refining technologies will be used to produce renewable fuels from
biomass

Engage with our business partners to ensure the stewardship and security of our products,
services and raw materials throughout their life cycles
 Honeywell suppliers, contractors and customers are evaluated to ensure the materials we
buy, manufacture and sell are packaged, transported, used and disposed of in proper
fashion to ensure the safety of people and the integrity of the environment
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
 Customer site audits
 Supplier evaluations
 Contractor evaluations
 Waste disposal site audits
 Understand and meet expectations for social responsibility
Through Hometown Solutions, Honeywell focuses its community involvement and
corporate giving on three specific areas: science and math education, family safety and
security, and housing and shelter.
 Local donation of fire fighting safety equipment
 Donation of breathing air compressor to local fire department
 Toy and canned food drive at Christmas for local food bank and Sparky’s
 Participation in local fundraising committees
 Participation in Detroit River Cleanup Committee

Work with all stakeholders for public policy and standards that enhance sustainability, act to
advance legal requirements and meet or exceed their letter and spirit

Site is actively involved in the CIAC Environmental Quality Committee

Promote awareness of Responsible care and inspire others to commit to these principles.
 Honeywell Specialty Materials subscribes to the Responsible Care® Global Charter
 We encourage our suppliers and customers to follow the same principles
 Encourage business partners and other local businesses to join CIAC and
subscribe to Responsible Care
 Educate our Community Advisory Panel and residents about Responsible Care
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APPENDIX 4:
FINDINGS REQUIRING ACTION AND OPPORTUNITIES FOR IMPROVEMENT
1. It is a finding requiring action to fully address the two findings, noted above, from the 2007
report.
1. There is an opportunity for improvement to complete the gap analysis and cross reference
process to determine what areas of the RCMS need to be bolstered by additional procedures
to attain compliance with CIAC requirements.
2. There is an opportunity for improvement to utilize the site SHARE related Total Recordable
Incident Rate data to benchmark and improve the sites employee safety performance.
(SHARE is an acronym for a CIAC sponsored Safety & Health Analysis Recognition and
Exchange)
3. There is an opportunity for improvement to more clearly link the site metrics to annual
improvement goals particularly the CIAC specified performance measures.
4. There is an opportunity for improvement to leverage the knowledge gleaned from the
documentation of emergency response procedure training/retraining and apply this
knowledge to the development of a process for all plant job functions.
5. There is an opportunity for improvement to document the process now used to determine the
frequency, content and expected outcomes of training for site emergency responders.
6. There is an opportunity for improvement to assess and document the training frequency for
Honeywell and third party security personnel that might be involved in emergency situations,
such as bomb threats and suspicious packages that originate outside the site perimeter.
7. There is an opportunity for improvement to amend the description of the Executive Contact’s
responsibilities to reflect the expectations of an Executive Contact of a CIAC member
company and an in- country representative of the parent corporation.
8. There is an opportunity for improvement to address any operational factors that prevent the
total support by workers of the site’s safety management systems.
9. There is an opportunity for improvement to amend SPO-RC-01 to require an annual spot
check of people, living and working in the worst case scenario impingement area, remember
what action to take in the case of an on-site event.
10. There is an opportunity for improvement to assess what specific risk communication might be
required for the local golf club and special event facility, the marina and any other group
community activities.
11. There is an opportunity for improvement to apply a Self Assessment (SAT) audit to the site
community dialogue process ,including risk communication, as an method of further support
to the annual Responsible Care® attestation process.
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CHEMISTRY INDUSTRY ASSOCIATION OF CANADA
Suite 805, 350 Sparks Street
Ottawa (ON) K1R 7S8
T: 613 237-6215 F: 613 237-4061
www.canadianchemistry.ca