Updated Responsible Care program wins carrier approval

Like Many fledgling attempts to enhance safety and efficiency in the transportation of hazardous materials, the Responsible Care Partnership program for tank truck carriers had to get out of the nest before it could test its wings.

Today, the program is soaring, according to several carriers that are participating in the American Chemistry Council-sponsored initiative. The program has now evolved into the Responsible Care Management System (RCMS), a much more robust means of measuring carrier performance.

“Our company (as a Responsible Care Partner) now says: ‘This is what we are going to do, here's how we are going to do it, here's how we are going to measure it, and our management will take regular reviews,’ “ says Lee Miller president of Miller Transporters Inc. “In Responsible Care parlance, that's the Plan-Do-Check-Act cycle. It's so simple it's brilliant.”

Miller Transporters is one of several tank truck carriers that are participating in the program — at various qualifying levels. Bulk Transporter contacted managers for comments about the Partners Program at Transport Service Co, Liquid Transport Corp, Tidewater Transit Co, Quality Distribution Inc, Schneider National Bulk, and Superior Carriers Inc.

George Peirce, vice-president of sales and marketing, chemical division, at Transport Service points out that the initial program implemented by the American Chemistry Council (ACC) for its members focused on how the chemical industry could improve its performance in environmental, health, safety, and security.

“As a bulk carrier we are a vital link in our shippers' supply chain to help meet these goals,” Peirce adds. “The ACC opened the Partners program in the 90s. We saw this as a positive step forward in working together with our chemical shippers on achieving those joint objectives.”

Program history

The history of the Responsible Care program began in 1988 when the ACC required all of its members to meet the program's commitments.

“Responsible Care helps America's leading chemical companies go above and beyond government requirements and openly communicate their results to the public,” says Dave Gleason, ACC senior director of the program. “The initiative is implementing world-class management systems, verified through independent auditors; tracking performance through established environment, health, safety and security measures; and extending these excellent best practices to business partners through the industry supply chain.

“The Responsible Care Partnership program extends the Responsible Care ethic beyond America's chemical product makers to their customers, shippers, and others engaged in the business of chemistry.”

Companies responsible for chemical transportation, distribution, storage, use, or treatment and disposal are eligible to become partners with the program. Those that are significantly engaged in chemical sales, marketing, and logistics may also be eligible. At present, there are approximately 70 companies participating in the Partner Program.

The partners adhere to the same Responsible Care requirements as members of the ACC. For example, all partner companies must obtain independent certification that the Responsible Care Management System (RCMS) has been fully implemented throughout relevant portions of their operations; functions according to professional standards; measure and publicly report performance; and fully implement the Responsible Care Security Code.

Carriers applying for the program have to provide two ACC member sponsors, and the carriers' senior executive must sign the application to indicate support to the project.

“Typically, an ACC member asks a carrier to join,” says Gleason. “The carrier must demonstrate to a third-party inspector that it is meeting the requirements. It takes a company one to three years to get it all in place. In the beginning, ACC will send out a special advisor to meet with the senior management team for the sole purpose of explaining the program — to make sure that there are absolutely no surprises relative to program commitments and timing.”

The initial application process may take one to three months, and achieving the management system certification may take up to three years after joining — with ACC member sponsors willing and able to assist in the process where requested. Immediately following approval by the ACC Board of Directors as a Responsible Care Partner, the new partner senior executive is required to sign the Responsible Care Guiding Principles, and the new partner initiates implementation of the Security Code. Progress is tracked routinely by the ACC until the Security Code is fully implemented — normally less than two years, but no longer than 2½ years.

The Guiding Principles address company ethics, operations safety, company safety culture, pollution prevention, and cooperation with governments at all levels.

The Security Code — which focuses on facility, cyber, and transportation security — requires carriers to conduct comprehensive security vulnerability assessments of their facilities, implement security enhancements, and obtain independent verification that those enhancements have been made. The Security Code also requires companies to create security management systems, which are documented to provide quality control and assurances.

The management segment of the program addresses seven key areas: community awareness and emergency response; security; distribution; employee health and safety; pollution prevention; process safety; and product stewardship.

Public reporting

One especially important aspect of the Responsible Care Partners program is its requirement for public reporting of a carrier's performance status, says Gleason. “Included in performance status is a product communication requirement,” he says. “Partner companies are required to have a communication system to facilitate public knowledge of their products, including relevant safety and risk management information. As part of this process, companies will provide opportunities for feedback and ongoing dialogue with interested parties.”

Responsible Care Partners don't rest on their laurels. They must re-certify every three years to maintain their qualifications. In the beginning, the program was not as rigorous in its requirements, and some carriers became disenchanted, particularly because companies were conducting self-auditing and there were no re-certification rules. But all of that has changed and carriers are singing the program's praises with few exceptions.

“The ACC realized that if they were going to put more teeth into their commitment to being a responsible care industry, they needed to go beyond self-auditing,” says Peirce. “The ACC incorporated the original six codes of management practices into the Responsible Care Management System. The system provides a structure around the Plan-Do-Check-Act model. Shippers and members have to maintain and be able to demonstrate utilization of specific processes in policy and leadership, planning implementation, operation and accountability, performance measurement, corrective and preventive action, management review, and reporting.”

With all the requirements and the costs associated with compliance, why would carriers want to go through the process? “With safety as one of our core values, being a partner made sense,” says George Grossardt, vice-president at Schneider Bulk. “We believe we have a responsibility to our customers and the public in addition to our company. One way to live this value is to take a leadership role in initiatives like Responsible Care. It's also good business. When we have processes that insure we are safe, we lower our costs. Lower costs are then translated into competitive pricing for our customers.”

Gary Watt, senior vice-president at Superior Carriers notes that the company has been a Responsible Care Partner company since 1998 and has taken an active role. “Similar to the ISO quality assurance standards, we believe ACC's Responsible Care initiative provides us with common procedures across our company operations as well as with the majority of our chemical customers,” says Watt.

“We originally decided to take part as a result of one of our customers who was a strong advocate,” says Pete Legere, vice-president, corporate training and development, who oversees the program at Liquid Transport. “If a company had completed this original process, the current process should not be terribly involved. The company should have most everything that's required in place, in one way or another. It's a matter of reorganizing to align yourself to the Responsible Care Management System's tech specs, turning in a series of annual metrics that a company should already have in place, as well as conforming to the Security Code, which should already be in place to meet federal regulations.”

At Tidewater Transit, Lance Collette, executive vice-president, says before the carrier decided to participate in the program, it had a quality structure and had been ISO 9002 certified. As it progressed to the management portion of the program, the process went smoothly. “In the transportation of bulk chemicals, we wanted a system that incorporated environmental responsibility, as well as other management guidelines that mirrored ACC guidelines,” he adds. “The RCMS did that and our system will follow the system adopted by our shippers.”

Peirce says that when the carrier began working on the management part of the program, much of the criteria was already established.

“We were able to achieve our RCMS certification over a six-month period,” he says. “The first step was getting our entire management team committed to making this happen. The second phase was going through all our systems and finding out where the gaps were that needed to be completed to meet the RCMS requirements. Selecting the right auditor was another key factor. We went through two phases of audits. The first to confirm we had all the processes in place and give us time to fill any gaps we had prior to going into the second phase, which was the actual audit.”

Miller says: “Initially, 12 years ago, it (joining the program) was at the request of two of our largest shippers. They thought it would be a good idea if we joined the American Chemistry Council, called the Chemical Manufacturers' Association at the time. I don't think that either they or us had any idea what we were agreeing to do at the time, and frankly, it was many years later before any benefit became evident.

“There were times as partners when, along with many other tank truck carriers, we failed to see anything beneficial from our association with Responsible Care. Still, there was something that held us there because even in the most confusing of times, we could see that if the program ever got traction, it would really be something of value…The ACC has invested in terrific resources for existing and future Responsible Care partners. The leadership is at an all-time strength and the program has its own specific steps of accountability and governance. In other words, you can't just write the check, put the logo on letterhead or equipment, and expect to stay a partner in good standing.”

Cynthia Harvey at Quality Distribution seconds her colleague's goals for safety and the benefits derived from qualifying for the Partners Program. “We are committed to the level of excellence required by our customers who themselves demonstrate and value excellence in safety and process,” she says. “We also considered the business value and benefits of being a Responsible Care certified partner, such as increased public perception, competitive advantage, increased community awareness, improved internal communications and morale, minimized risk, and compliance management.”

To become certified, Quality Distribution underwent a one-year evaluation process that included environmental, health, safety and security management system documentation review, rigorous series of audits, personnel interviews, and clearance of non-conformance issues — all of which worked to identify corrective actions that eliminate non-conformance with the management system. An independent registrar performed all evaluations during this process. Following completion of this process, the company received its recommendation for certification.

At Schneider National Bulk, Grossardt credits the company having already qualified for ISO certification as a foundation for meeting the Partners Program requirements. “We adapted our current processes to the Responsible Care protocol and successfully passed our audit for certification,” he recalls.

“The process was very involved even though we started with a proven quality structure,” says Collette. “Our quality director, Ricky Johnson, spent numerous hours writing and rewriting some of our policies and procedures to comply with RCMS guidelines. We had a pre-audit (assessment audit), a secondary audit, and a certification audit. There was a significant management commitment to the process and system.”

Watt points out that the RCMS audit is a complex process that reviews and validates the company's understanding and implementation of Responsible Care procedures relative to the transportation, handling, safety, and security of chemical products. “Similar to the third party audits required to sustain ISO quality assurance certification, the RCMS audit applies to both our corporate office as well as terminal network to insure consistent application across the corporation,” he adds. “ACC provided assistance prior to the RCMS audit to help us understand the scope of the audit and integration with our existing processes and procedures. The actual RCMS audit was in-depth, very detailed, and conducted at both our corporate office as well as a representative sample of terminals selected by the auditor.

Watt also notes that Ken Sevcik, Superior Carriers vice-president, quality assurance, serves on the Responsible Care Partner Companies Steering Committee and is currently committee chairman.

Worthy efforts

Despite the manpower and costs associated with qualifying for the program, the carriers agree the results were worth the effort. Some note that the processes they experienced also produced unexpected results. Peirce says that the effort helped the carrier's entire staff focus on overall environmental, safety, health, and security issues, and keeps those issues in the forefront of every-day operations.

“We made a conscious effort when we went into this process that this was not just another program to meet ACC requirements, but a process that Transport Service will use to be a better carrier, and it already has,” Peirce says. “Going through our gap analysis we found things that we needed to change. We have made those changes and will continue to evaluate our process for continued improvement.

“This whole process cost us a great deal of time and money to achieve. Some of the member (chemical) companies recognize this and will only use certified carriers. We are seeing more shippers sponsoring partners and in some cases offering monetary awards for achieving their certification. Having completed our certification should eliminate the numerous audits we receive from various chemical companies.

“The real value will be when all the member companies require their carriers to be certified partners.”

Watt adds: “The primary internal benefit of the RCMS audit process is assurance of our application of common procedures across our operations relative to the transportation, handling, safety and security of chemical products. Externally, the RCMS process further evidences our commitment to both our customers and the public at large to provide our transportation services in a safe and secure fashion.

“As well, the RCMS audit process better aligns us with our chemical customers toward common goals for the transportation, handling, safety and security of their products. Finally, we have already seen the benefit with several customers that eliminated individual customer audits, thus saving both companies time and expense for both parties.”

Miller agrees that the benefits of the program have been both tangible and intangible. “Tangibly, we have formalized many of our internal processes as they relate to health, safety, security, and the environment,” he says. “We have always felt that we had programs that were among the best in the industry in these areas, but now we can objectively point to specific steps that have been taken to formalize them. We had a less formal approach to things prior to certification, but now we have etched it in granite that this is what we will do.

“Intangibly, it gives confidence, encouragement, and strength to the organization by knowing that we have a plan — that the plan is devised through some disciplined approaches to empirical data. The results of the plan are specific, actionable, and accountable. Having this overarching our processes is foundational. In addition to having these steps in our health, safety, security, and environmental processes, we have used the same techniques in other areas such as operations and maintenance.”

Legere lauds the program benefits by saying the greatest advantage is that it forces a company to regularly and carefully look at the policies and procedures related to Responsible Care and to continually meet program commitments. “It offers an oversight of a sort,” Legere adds. “It's very easy to drift and to take paths of least resistance — especially in as busy and competitive a business as ours. Responsible Care becomes a mantra to remind everyone who may need reminding that safety cannot be compromised to profit nor customer demands.”

And, he adds, the reality of a third-party audit on the horizon is another reminder. “We all pay attention to audit items, no matter how busy we are,” he says.

Another bonus is that ACC members recognize the certificate, thus reducing the surveys and customer audits that, in themselves, can be very time consuming, repetitive, and expensive. “It opens up dialogue among partners and members to talk about common problems and issues within the service chain,” Legere says.

“Some customers are requiring certification in order to do business. It doesn't guarantee you any business, but it allows you to compete for it.”

Grossardt agrees that the most direct benefit of the program is consistent re-evaluation of processes to insure the carrier is operating in a manner consistent with its values. “Accidents often happen as a result of complacency,” he says. “That's why they are called accidents. This process checks for actions against predetermined processes. Out-of-tolerance actions can then be addressed. This insures we are diligent in providing safe service to our customers and the public.”

At the same time, Grossardt points out that the process is still in its infancy for the carrier community. “We are still seeing shippers that are RC practitioners ask us for additional audits even after we have successfully completed RC certification,” he says. “This is probably because the shipper and carrier communities haven't spent enough time insuring that there is universal understanding of what being certified means yet. All RC partners can save time and money by accepting certification at face value. We believe this will change over time.”

Harvey says that the management certification recognizes that the company's policies, practices, and procedures ensure the safety of its operations, enhance the quality of its services to customers, minimize the environmental impact of its activities on employees and surrounding communities, and continually improve its performance.

All and all, the Responsible Care Partners program seems to have garnered a winning vote from its carrier members. Should other carriers consider applying? Miller has one answer: “Do it — that is if you do it for the right reasons. It will contain an incredible payback for you. The right reasons for doing this are to strengthen your company and its vital processes. The wrong reasons include doing it to get certified, get the shipper off your back, checking the box, or anything that reeks of going through the motions.”

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