By Alexandra Pecci and Amanda Sawit
The American Chemistry Council strives to promote safe, sustainable, and responsible supply chains.
When Debra Phillips was at her last job at a chemical company, her firm would conduct self-evaluations to keep track of its process, occupational, and environmental safety performance. And while she may have considered that approach to be pretty state of the art in 1996, steady progress over the past 20 years for responsible supply chains sets the stage for continued and accelerated progress over the next 20.
Right: Debra Phillips, ACC’s vice president of Responsible Care. Photo: Ana L. Ka’ahanui
Now, as the American Chemistry Council’s (ACC) vice president of Responsible Care, Phillips oversees the flagship performance initiative for ACC member companies to promote safe, responsible, and sustainable management of chemicals through their life cycles and for their intended uses. Responsible Care aims to not only keep up with, but also set, the course for the chemical industry related to improving employee safety, environmental protection, and the health of the communities in which the industry operates and which it serves.
“In the United States, we aim to go further than regulatory requirements,” Phillips says, noting that Responsible Care often sets the bar for what the government eventually mandates. And when it comes to establishing regulations, “We’re often at the table being consulted,” she says.
Responsible Care and the Product Safety Code
Since its establishment in Canada in 1985 and adoption in the United States in 1988, the Responsible Care program has grown at the pace of the chemical industry and the world at large.
Among the watershed events that led to the program’s inception was the 1984 Bhopal disaster in India, which “really raised public awareness … and accelerated the industry’s efforts in this area,” says Phillips. Although these issues became a part of the public policy debate in the aftermath of the disaster, “industry at the CEO level … didn’t wait for legislation or regulation,” she adds. “They took the issues surrounding this tragedy very seriously.” In the years that followed, the chemical industry grappled with performance challenges and began to develop their own safety and emergency planning processes as some of the key environmental statutes in the U.S. were coming online.
Responsible Care operates with several guiding principles, which broadly include how products are designed, developed, manufactured, transported, used, and disposed of or recycled safely. It also gives guidance for secure use and transport of chemicals; safe and environmentally sound facilities; risk, health, safety, and environmental research and communication; responsible environmental practices, and more.
“I think there’s no other industry voluntary program that has the breadth and depth of Responsible Care,” says Phillips. “One by one, countries around the world started adopting the program.” Although the program is technically voluntary, adhering to Responsible Care standards is a condition of ACC membership, which Phillips says is unusual for a trade association. She says she often hears from other trade groups who say, “We could never do that.”
In the decades since its establishment, Responsible Care has spread to more than 60 countries and accrued an impressive safety and environmental record. According to ACC, Responsible Care companies have reduced process safety incidents by 53 percent since 1995, cut hazardous releases to the air, land, and water by more than 78 percent between 1988 and 2013, and lowered recordable injury and illness rates by 78 percent since 1990.
For ACC member companies like Olin Corporation, “Meeting just the minimum requirements has never been good enough,” says Maria Krysa, director of Olin Responsible Care and Quality. “Responsible Care is a management system and it makes sure there is a robust, comprehensive approach to looking at the risks of the organization and the resources needed all the way down to implementation.” Krysa was, in fact, drawn to Olin because of its commitment to Responsible Care, which she says embodies “doing things responsibly.”
Responsible Care is always expanding to be more transparent (including performance reporting that is published on ACC’s website) and stringent in its standards, and one of the program’s strengths is that it has mechanisms to deal with noncompliance. Although there have been a few instances where companies have missed the mark, Responsible Care’s governance processes allows for peer assistance and additional time for members to improve their performance. “Our companies are really committed to transparency,” Phillips says. ‘”They have a dedicated CEO commitment.”
Equally important to the Responsible Care program’s current principles and requirements are future opportunities. With the phased introduction of the Product Safety Code, which began in 2013, the next evolution of Responsible Care is currently underway. The code introduces a set of 11 practices designed to require chemical manufacturers to evaluate and continuously improve product safety performance and make information about chemical products publicly available. The introduction of the Product Safety Code dovetails well with the increased awareness that buildings industry professionals have of supply chain issues and, when fully implemented, may provide industry with a tool to help facilitate information exchange and increased understanding of the safety of chemical products.
Phillips also sees room for continued improvement. For instance, she says, Responsible Care does not currently cover many social issues, such as anticorruption mechanisms, workplace diversity, and child labor. “The question is, why not?” she says. She also notes that more work could be done to communicate and manage product-level information for consumers, such as a certain product’s carbon footprint; whether it can be recycled; and how much water was used to make it.
In its work with the U.S. Green Building Council (USGBC) on supply chain transparency, Responsible Care seems to be helping the industry move closer to some of those goals.
“It’s part of the industry’s culture,” Phillips says.
Supply Chain Transparency
The product-related decisions made by building industry professionals typically involve materials that are the result of a complex, interconnected, global supply chain. Even for the relatively mundane products, these chains often involve four tiers of suppliers and more than a dozen individual material supply companies; chains for more complex materials can easily be double or even three times as diverse.
As industry becomes more aware of the inherent challenges to specify products that balance performance trade-offs between form, function, cost, environmental and health considerations, industry professionals increasingly find themselves concerned with decisions made further up the supply chain—now more than ever before.
Project teams are now asked to consider and understand products, and the raw materials that go into them, in a more comprehensive way. With the latest version of Leadership in Energy and Environmental Design (LEED v4), USGBC is also encouraging product manufacturers to proactively engage their customers in conversations about supply chain issues. Fortunately, key participants in the buildings products supply chain are helping suppliers meet this new challenge.
In 2015, an integrated group of stakeholders was charged with developing implementation procedures for the “supply chain” option of the Materials & Resources credit for Building Disclosure and Optimization – Material Ingredients credit in LEED v4. This option was created to promote the environmental, health, and safety management of products throughout the supply chain. USGBC and ACC collaborated with chemical suppliers, building product manufacturers, design teams, academics, and government entities to produce guidance (distilled in the Product Manufacturer Supply Chain Optimization option) to encourage entities within the supply chain to scrutinize the management of chemical ingredients that are used to make an end product. It also encourages manufacturers to evaluate and manage existing materials and seek better alternatives when possible.
“The Responsible Care program coupled with the Product Safety Code offered the working group a better understanding of how environmental management systems operate up and down the supply chain and how we can use LEED to reward innovation and optimization,” says Brendan Owens, chief of engineering for USGBC.
The conversations that are necessary to make good decisions around product transparency and optimization should not be oversimplified. “There is no such thing as ‘green’ or ‘brown’ product. Throughout the extraction, manufacturing, use, and reuse continuum you’re faced with trade-offs, which are never simple. Low global warming potential in a product sometimes comes at the expense of less than desirable human health aspects—and there are dozens of metrics on which this type of analysis can be conducted,” says Owens.
Responsible Care, Product Safety Code, and other similar programs are key infrastructure that allow manufacturers to internalize and systematize safety and sustainability. LEED credits are designed to highlight the data that make trade-off analysis possible. USGBC’s collaboration with ACC, whose member companies possess some of the information that must be considered during decision making, augments the effectiveness of the LEED v4 credits.
Armed with the information and tools to make informed product selection decisions, end users can start to specify products that influence what the market provides and, in doing so, reward innovation further up the supply chain. When designers, architects, and builders communicate preferences for product quality and safety baselines as Responsible Care does, they enable manufacturers and suppliers to demonstrate their commitment to a common goal.
End users can also use their influence to identify and support those who are ensuring the safety and quality of the products they use. “The consumer is out there hoping for the best product in the world,” says Stephen Torres, who sits on the Responsible Care committee and is the Safety Director for Schneider Bulk Carriers, a truckload, intermodal, and logistics provider. Moving forward, he would like to see greater public recognition of the actions that manufacturers and suppliers are taking—like participating in Responsible Care—to ensure responsibility and stewardship for the environment. “Ultimately our goal would be to get that out more,” he says.
The credits reward innovation by giving upstream companies that are performing hazard and exposure assessments the ability to differentiate themselves. “We are always looking for the best and fastest way to accelerate market transformation, from the project itself to the products used,” says Mahesh Ramanujam, COO of USGBC. “The best way to do this is for the manufacturing industry to take the lead and continue to implement holistic, life-cycle based decision making.”
Olin’s Chlor Alkali business is proud to be a Responsible Care company. Responsible Care is a global initiative aimed at minimizing any negative impact from the manufacture, distribution, and use of chemicals, while maximizing the beneficial use of our products in society.