responsible care - Chemistry Industry Association of Canada

Transcription

RESPONSIBLE CARE®
Verification Report
Harmac Transportation Inc.
April 26 - 27, 2011
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
This report documents the observations and conclusions of the independent verification
team tasked with conducting a Responsible Care Verification of Harmac Transportation
Inc. The verification was carried out on April 26 and 27, 2011 and included team vis its to
their headquarters and Transportation terminal in North York, Toronto and Transportation
Terminal in Burlington, Ontario. This was the third Responsible Care verification
completed for Harmac Transportation. The last verification was completed on April 28,
2006.
As a result of the exam ination conducted, the verification team is of the opinion that the
Responsible Care Ethic and Principles for Sustainability are guiding company decisions
and actions, and that a self-healing management system is in place to drive continual
improvement. The team believes that the company is capable of responding to the range
of Findings Requiring Action identified during the verification - summarized below and
discussed in detail in the report. The verification is complete and no further involvem ent is
required by the verification team .
Date: June 23, 2011
Signed:
Alec Robertson
Verification Team Leader
For more information on this or a previous Responsible Care Verification Report, please
contact your local company site or the company’s Responsible Care executive contact:
David MacDonald,
V.P. Chem icals & Business Development
(902) 482-2403
[email protected]
Re-verification report for Harmac Transportation Inc., April 2011
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SUMMARY OF VERIFICATION TEAM OBSERVATIONS
Following is a listing of the 7 Findings Requiring Action, 12 Bes t Practices and 2 Extra
Miles found in the body of the report. Progress on action to resolve the Findings will require
follow-up at each Leadership Group Meeting, with the local CAP(s), and in the company’s
annual CEO re-commitment to CIAC. These will also be, along with the decisions
pertaining to the 34 Opportunities For Improvement, attached as Appendix 4 as well as in
the report text, reviewed during the next Responsible Care re-verification. The wording of
each Finding Requiring Action, Opportunity and other comm ents found in this Summary
and Appendix 4 is identical to the wording used in the body of the report to a void any
possible misunderstanding of the team’s intent.
Findings Requiring Action
1) Complete the documentation that describes the overall Responsible Care
Management System in terms of the plan-do-check-act continual improvement
cycle, as described in the CIAC document entitled “Responsible care for
Transportation Partners – A new model for enhancing value” - This could be
incorporated into the existing management system document.
2) Develop a management system around the Environment Responsible Care code
elements.
3) Develop a management system around the Community Awareness aspect of the
TransCAER Responsible Care code elements.
4) Complete the cross referencing of the themes and sub themes of the
Transportation Partners Responsible Care model to the relevant management
systems and operating manuals.
5) Implement a documented process, utilizing the above cross referencing, to
perform an annual assessment to substantiate the annual affirmation to the CIAC
that Responsible Care is in place.
6) Document, in the management system, the requirement to annually test through
an appropriate exercise, the effectiveness of the security management system
and its processes.
7) Document the requirement for, and implement, an annual emergency exercise
program to validate and maintain the effectiveness of the emergency exercise
management system and its processes.
Bes t Practices
1) Tractor deceleration rates of 9 mph/second trigger an information download for the 60
seconds pre and 40 seconds post the event. This capability has proven valuable to
Harmac in incident analysis and they have been told that they are ahead of the curve in
adopting this technology.
2) The robustness of the incident/accident inves tigation protocol utilized to capture even
the most minor of incidents.
3) The Driver Scorecard system.
4) The ver y comprehensive suite of performance metrics focusing on driver behaviour.
5) The overall commitment towards performance improvem ent – in some cases by 25% in
their quest to zero.
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6) Violation rates on Harmac’s current Ontario CVOR and US Dot carrier profiles are
significantly below the monitoring thresholds.
7) The PeopleNet data management and On-Board Truck Computer (OBTC) systems that
record driving activity and allow for the use of e-mail communication, electronic driver
logs, incident flashes and truck operation analysis are an industry bes t practice.
8) Tractors governed to 102 km/hr, both on pedal and cruise.
9) The VORAD system for sensing blind spot encroachment.,
10)The ‘Diesel Talk’ program, a motivational CD series, provides drivers with information
on transportation related health and safety issues.
11)The “pinging” back to dispatchers when posted driving speeds are being exceeded.
12)Well defined driver training program including the use of a well recognized driver
training process (Smith system) for initial, annual refresher and two year repeat driving
skills training.
Extra Miles :
1) The 72% reduction in preventable vehicle accident rates over the past 5 years.
2) The focus on technology to im prove road safety.
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1.
INTRODUCTION AND OVERVIEW
1a)
The company
This is the report by the verification team on those operations of Harmac Transportation
Inc., which are covered by the company’s commitment to the Responsible Care initiative of
the Chemistry Indus try Association of Canada. A des cription 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 Indus try Association of Canada 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 50 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 b y 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
risk s and b enefits 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.
For transportation partners the ethic is supported in Canada by a Responsible Care Model
covering relations with the communities where the partners operate and also responsible
management throughout all aspects of those operations. Information on the model 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 transportation partners
Each transportation partner of the CIAC mus t formally commit to the Responsible Care
Ethic and the Transportation Partners Responsible Care Model, 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 transportation partners for implementation.
The association monitors progress and follows up by arranging for assistance where
necessary to ensure that each company eventually meets its commitment.
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When a transportation partner considers that its management processes are sufficiently
comprehensive that they meet all of the requirements of the Responsible Care Model, it
advis es the association that implementation is complete to the stage of “Responsible Carein-Place”. Completion in this sense does not imply that nothing further needs to be done,
but that a key milestone has been reached in a process of continuous improvem ent.
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 transportation partners and others including
several critics of the industry and its operations. The first verification takes place when the
company firs t states that its performance meets the expected level (Responsible Care-inPlace). This verification is designed to confirm, for the company’s peers in CIAC and the
public, the exis tence of a company-wide ethic and management systems which ensure that
the principles and specific requirements of the Responsible Care Model 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 ongoing re-verification.
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’s national
advis ory 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, the requirements described under each theme
contained in the Responsible Care Model are sampled in depth using a series of questions.
The questions are sent to the company in advance of the verification vis it, so that initial
responses can be prepared for prior review by the verification team and supporting
documentation, etc. can be available for prompt exam ination 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 exam ine the senior level intent and the corresponding support by action at the operating
level.
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Ques tions are generally of the following nature:
 does the organization have an effective management system in place to ensure
understanding of Responsible Care?
 what is the process to determine and communicate the acceptable level of
performance?
 what is the process for assessing the performance of the system and effecting
follow-up to meet or exceed the acceptable level of performance?
 what is the process for ensuring up-to-date documentation?
 do sufficient resources appear to be, or are thought by employees to be, in place?
The findings are summarized in a report which highlights:
 actions required by the team before they consider the company meets the
expectations of Responsible Care;
 opportunities for improvem ent, which are recommended but not mandatory;
 recognition of any exem plary practices of the company which could be a model for
other CIAC trans portation partners.
The report is given to the company and CIAC, and the company is expected to share the
report with interested persons in its communities as part of its dialogue process. If the team
considers that actions are required before sign-off, they will arrange for follow-up to confirm
that these are complete, and advise the company and CIAC in writing when these have
been met to their satisfaction.
Responsible Care-in-Place verification of Harmac Transportation Inc.
Company nam e at time: Harmac Transport Corporation Inc.
Date of verification (vis it): October 16 – 22, 2003
Locations vis ited:
Head Office Toronto, Transport Terminal, Corunna, and Parking
Facility, Brock ville, all in Ontario.
Team follow-up needed: No
Date of final sign-off:
December 6, 2003
This Responsible Care-in-Place verification report is available from the contact at the
company from whom you accessed this report, or from the company contact shown on
page 2 of this re-verification report.
1d)
ii) Re-verification
Approxim ately ever y 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 exam ine 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 Plan-Do-Check-Act parts of the management
system).
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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 e ver y
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 vis it stage of
the verification, at which a schedule is agreed covering people the team wishes to interview
in depth during the subsequent vis it stage of the verification process. Mos t 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 exam ination 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
obligations of the Responsible Care Model 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 exam ined, 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 exam ines 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 transportation partners has suggested the value of a
closer examination of the general partners performance and comparison with the intent of
the requirements of the Responsible Care Model. 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 exam ples from which
others can learn.
The highlighted topics are Operations Safety, Supply Partner Assessments, Greenhouse
Gas Emissions, Security, Emergency Res ponse and “TransCAER” outreach. 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.
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Responsible Care Re-verification of Harmac Transportation Inc.
Company nam e at time: Harmac Transport Corporation Inc.
Date of verification (vis it): October 23 – 26, 2006
Locations vis ited: Head Office in North York, Ontario; transportation terminals in
Montreal, Quebec and Kingston, Ontario; truck parking facilities in London and Hamilton,
Ontario; and a truck washing facility in Oakville, Ontario.
Team follow-up needed: No
Date of final sign-off:
February 26, 2007
For more context or e xplanation of any of the item s below, please get in touch with the
contact at the company from whom you accessed this report.
The report below presents the findings of the team from this re-verification of Harmac
Transportation 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 transportation partners as possible exam ples.
In the following sections of this report, findings requiring action are shown in bold face.
Opportunities for improvement (recommended b ut 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 vis ible and at work in the company, guiding the company’s judgement,
decisions and actions.
FINDINGS
Overview:
The Responsible Care ethic continues to be well understood and clearly guides company
actions and decisions
The Executive contact is ver y committed to Responsible Care and has the full support of
the company President and COO. A strong Responsible Care core and extended team has
been formed and all members of the team have fully embraced the ethic and principles.
Although the recent recession had slowed the full development of documented
management systems to support Responsible Care, the company continued to operate
with an effective Plan Do Check Act management cycle.
Responsible Care promotion has improved since the previous re-verification by broader
use of the logo in corporate website upgrades, commitment plaques being posted in office
and garage work areas, in marketing literature etc.
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Those interviewed, at various levels throughout the organization, were very open to the reverification process and displayed a significant commitment to road safety and to fulfilling
the requirements of Responsible Care.
Opportunities for Improvement:
i) Ensure that all opportunities for improvement identified in the 2006 re-verification report
have b een appropriately considered and addressed with the results documented.
ii) Add Responsible Care signage (e.g. external banners and/or flags) to assist in b randing
Responsible Care in the community.
iii) Consider migrating Responsible Care to the rest of the transportation companies within
the Seaboard/Harmac group - Seab oard, GWR, Foss and the US com pany – AJ
Weigand b y ensuring and communicating that, while it is a CIAC initiative to which
Harmac formally sub scribes, the ethic, principles and expectations are sub scribed to
throughout Seaboard and reflected in processes in place throughout the company.
iv) Communicate this re-verification report to the North York community through the local
Business Improvement Area (BIA) organization.
2b)
Employee Awareness
Here the team considered how much the employees interviewed are aware of Responsible
Care and understand how the ethic underpins the company’s and employees’ own actions
and decision-making. Als o taken into account was the vis ible evidence of Responsible
Care and the ethic.
FINDINGS
Overview:
Using an in house orientation slide program, all Harmac employees have received
Responsible Care training/retraining since September, 2010. The re-verification team
interviewed Health and Safety Comm ittee members and various other employees during
our site vis its. They uniformly displayed a good understanding of Responsible Care and
what this meant to them in their day to day work activities.
Opportunity for Improvement:
i) Document employee Responsib le Care training/retraining expectations and include in
the training management system .
2c)
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, the model and other expectations of
Responsible Care on an ongoing basis. A sound management system drives continuous
improvement, and has the following attributes:
Plan - review Responsible Care Model requirements
- benchmark best practices
- get input from stakeholders
- decide on best approach
- set targets for performance
- assign responsibility
Do
- document
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- 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 specific requirement as defined by the Res ponsible Care Model.
This section 2.3 covers the team’s findings with respect to this overall management
system, and section 3 below covers the specific requirements of the Responsible Care
Model that were reviewed in the re-verification.
FINDINGS
Overview:
The company organization is structured in such a way that top down corporate objectives
and bottom up performance results are passed through the various business units, orbits
and management levels in a very efficient manner, with clear responsibilities outlined and
results based recognition systems evident throughout.
The company’s management system addresses the four Responsible Care themes as
defined for CCPA transportation partners. Responsible Care, Environment, and Safety
policies, which set the strategic direction for the company, are in place, and supported by a
series of documented practices and procedures. The company is a member of the Ontario
Trucking Association and the National Tank Truck Carriers Association in the U.S.A. and is
also registered under the ISO 9001-2000 Quality Managem ent System Standard and
undergoes external audits against this standard.
A recognized service provider is utilized to stay abreast of current and emerging regulatory
requirements and other related aspects of the transportation industry.
Notwithstanding the above, limited progress was made in addressing both the Findings
Requiring Action and Opportunities for Improvement identified during the previous reverification until recently. Bus iness challenges presented by the turndown in the overall
economy and the integration of newly acquired companies during intervening years were
reportedly the prim ary causes. However, organizational restructuring that took place during
the past year has enabled increased focus on Responsible Care and the areas requiring
improvement documented in the previous re-verification report. Mos t significant amongst
organizational changes impacting Responsible Care was the creation of two vice president
positions for Seaboard/Harmac. The Chemical liquids and Business Development VP,
David MacDonald, joined the company in September, 2010 and subsequently assumed the
role of CIAC’s Executive Contact from Seaboard’s President, Mark Shannon. Core and
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Extended Leadership teams were subsequently established and have been conducting
management reviews of exis ting systems and processes as they relate to the Responsible
Care themes. These reviews will form the basis for upgrading various aspects of the
corporate management system for better alignment/inclusion with Responsible Care codes
and expectations.
Findings Requiring Action:
i) Complete the documentation that describes the overall Responsible Care
Management System in terms of the plan-do-check-act continual improvement
cycle, as described in the CIAC document entitled “Responsible care for
Transportation Partners – A new model for enhancing value” - This could be
incorporated into the existing management system document.
ii) Develop a management system around the Environment Responsible Care code
elements.
iii) Develop a management system around the Community Awareness aspect of the
TransCAER Responsible Care code elements.
iv) Complete the cross referencing of the themes and sub themes of the
Transportation Partners Responsible Care model to the relevant management
systems and operating manuals.
v) Implement a documented process, utilizing the above cross referencing, to
perform an annual assessment to substantiate the annual affirmation to the CIAC
that Responsible Care is in place.
i) With Responsib le Care being first and foremost an ethic, not a program (often displayed
as an umb rella), this should be communicated at the b eginning of the management
systems document. Responsible Care specifics could b e further described with other
programs or processes in place elsewhere in this document.
ii) Document Responsible Care responsibilities in appropriate employee job descriptions.
iii) The Team suggests that Harmac’s management of change process includes
organizational changes for positions with Responsib le Care responsibilities.
iv) Include Responsible Care expectations in the assessment process for potential new
customers.
2d)
Follow-up on Findings in Last Verification Report
The team reviewed how the company addressed the findings requiring action and
opportunities for improvem ent cited by the previous verification team in their report to the
company. Certain follow-up items are covered in the specific topics below.
FINDINGS
Overview:
There were eight findings requiring action from the previous verification and a greater
number of opportunities for improvement. The company issued a letter to cus tomers,
informing them that the re-verification had been successfully completed. No requests were
received for the report itself or for additional information on it.
Comments on the follow up of items in the previous report are included in section 2a) of
this report above.
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2e)
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.
FINDINGS
Overview:
The company uses an in-house developed incident investigation system which focuses on
identification and analysis of the root causes of all incidents. With the bulk of the
corporation’s incidents involving the road transportation of products, the inves tigation
processes are tailored primarily for trans portation incidents. The on board truck computer
(OBTC) is designed to capture vehicle operating information (e.g. vehicle speed, vehicle
location, braking data) prior to and at the time of the incident which, when combined with
police reports, scene photos etc provide the input information necessary to do an accurate
incident re-construction and analysis.
Action and closure of incidents affecting the petroleum side of the business is tracked
directly from a safety database used to track incidents and concerns. Issues affecting the
chemicals business are moved to another database where they are stewarded to closure.
A unique feature of the system is its ability to generate an e-mail incident flash which can
be broadcast to appropriate management team members as well as to drivers over the
OBTC system. Health, safety & en vironmental issues are also tracked to closure by the
HSE management system. There is a weakness in that the safety database does not
adequately reflect the final disposition of all incidents to show that the issue has been
addressed and closed, nor is there a mechanism to reflect that remedial action taken was
indeed effective, after im plementation.
The overall effectiveness of the comprehensive suite of technologies and management
systems utilized is evidenced by preventable accident rates having decreased from 0.25 to
0.07 per 100,000 miles over the past 5 years, a remarkable 72% reduction.
i) The company should ensure that the safety database reflects the final disposition and
closure of all incidents and concerns that have b een reported into the database
including those that have been handed off to other control system s for resolution.
ii) Harmac are encouraged to continue their initiative to identify and implement
improvement initiatives to reduce product handling incident rates.
Bes t Practices:
i) Tractor deceleration rates of 9 mph/second trigger an information download for the 60
seconds pre and 40 seconds post the event. This capability has proven valuable to
Harmac in incident analysis and they have been told that they are ahead of the curve in
adopting this technology.
ii) The robustness of the incident/accident inves tigation protocol utilized to capture even
the most minor of incidents.
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Extra Mile:
i) The 72% reduction in preventable vehicle accident rates over the past 5 years.
2f)
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 items – injuries, train accidents, fuel efficiency, non-accident
releases and TransCAER events – CIAC specifies measures for reporting under
Responsible Care. Mos t other areas are left to the dis cretion of each transportation 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.
FINDINGS
Overview:
The company tracks personal injury rates; accident rate per million miles driven; number of
product spills and contaminations; and out of service percentages relative to regulatory
roadside inspections. Improvement in these areas continues as they continue to implement
specific safety initiatives .
While their primary benchmarking process is against their own historical performance,
company violation status vs. industry benchmarks is readily available via Provincial
commercial violation operating record systems in Canada (e.g. CVOR In Ontario) and US
Department of Trans portation (DOT) records in the US. Harmac reviews this information on
a monthly basis to ensure that all violations recorded have been reported by drivers to the
company, to ens ure that there are no errors in the data compiled and to assess their
ongoing performance against their own history and industry norms . Harmac’s current
violation rates on the Ontario CVOR (pas t 24 months of data) are 22.2% of the monitoring
threshold with similar overall performance being recorded on the recent US DOT report.
Benchmarking is also addressed through the National Tank Truck Carriers Association,
which compares performance for similar sized carriers within its membership.
A dri ver scorecard program is currently being rolled out to all orbits. Data provided by the
comprehensive data gathering by tractor on board computers is a major input to the
system. Scorecard information is currently being shared with drivers for self improvement
and comparison data provided for individual comparisons to group averages and company
benchmarks. In areas where the system implementation is more advanced, it is proving to
be of considerable value for recognizing and rewarding good driver performance and in
identifying areas of improvement for others.
i) There is an opportunity for the company to complete the linkage of driver scorecard
performance to the form al performance evaluation process and driver b onus program
across all divisions.
ii) Identify and implement a consistent driver incentive program for the entire organization,
specifically across the different operating companies.
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iii) There is an opportunity for the company to develop a formalized industry performance
benchmark process with performance targets established for various identified
measurement areas.
iv) Add additional b road b ased indicators to the current slate of performance measures.
(e.g. completion of planned events and activities such as for TransCAER, emergency
response drills, and outreach; and tracking of public concerns received).
Bes t Practices:
i) The Driver Scorecard system.
ii) The ver y comprehensive suite of performance metrics focusing on driver behaviour.
iii) The overall commitment towards performance improvem ent – in some cases by 25% in
their quest to zero.
iv) Violation rates on Harmac’s current Ontario CVOR and US Dot carrier profiles are
significantly below the monitoring thresholds.
3)
TEAM FINDINGS FOR SPECIFIC MANAGEMENT SYSTEMS
3a)
Operations Safety
The team looked at how the hazards and risks from potential episodic ('s udden') incidents
are identified and controlled throughout the company’s operations, including awareness
and understanding of the methods used for assessment and the techniques for hazard
control, and how these are applied and kept current.
FINDINGS
Overview:
Safety at Harm ac is given top priority. Annual environment health and safety objectives are
es tablished, with performance tracked against these and reviewed monthly by functional
personnel and senior management. The company has a published safety policy and a ver y
detailed and extens ive Driver’s Guide that outlines safe practices for all aspects of the job.
There are a variety of dri ver training programs, including orientation of new drivers that
includes Responsible Care, TDG, em ergency response, defensive driving and mentoring.
Incident flashes via the On-Board Truck Computer (OBTC) system keep drivers aware of
safety issues on an ongoing basis.
Company vehicles make use of leading edge equipment and technology to enhance safety
while on the road. OBTC’s gather extens ive equipment trip operational data and, in concert
with the linked PeopleNet data management system, record driving activity and allow for
the use of e-mail communication, electronic driver logs, incident flashes and tractor
operation analysis. A unique capability is that the system “pings back” to dispatchers when
speed limits are exceeded in any of 4 identified speed zones. These four zones represent
39% of areas where issues/incidents occur. Latest dispatch control technology (TWM
system) is used to prevent drivers from being dispatched when their qualifications expire,
available hours of service are not sufficient to complete the planned trip or when they are
not product qualified. Started in 2006, BASE pas sive shutdown systems have been
installed on propane tankers to monitor and automatically shut down the offload process
when abnormal pressures occur. This was well before such systems were mandated.
Page 15 of 28
Transportation route risk assessments are carried out on new delivery routes and where
new commodities are to be carried. Detailed Journey Managem ent Plans and/or site
management plans are also used for selective/strategic locations. There is also a process
in place to determine if in fact the company can handle products that that have not been
handled in the past. The company has refused to carry some specific commodities as a
result of the above assessment.
Tractors and trailers are maintained by company pers onnel with occasional outside
contract shop support. Preventive maintenance scheduling is managed by a computerized
system. Controls are also in place to ensure that owner operators maintain their equipment
on a scheduled basis. Tank cleaning is done at pre-qualified external tank wash facilities.
Under run protection has been selectively ins talled, and anti roll over technology has
become standard, on new company petroleum B- train units. A ‘Tire Ma x’ system is also
utilized. It senses and maintains tire pressures using tractor compressor supplied air.
There is a formalized management of change process in place for changes to plant and
equipment.
Health and safety committees, or the equivalent, are in place at term inal facilities. A unique
initiative is that monthly Joint Health and Safety (JHSC) meetings are held Ontario-wide via
teleconference and include locations that are not required by law to have a JHSC. Driver
participation impacts the amount of their safety bonus. There is also a job audit program in
place which is specifically applied to driving operations. At least once per year each driver
is accompanied by a member of management and their driving performance assessed.
Observations by management personnel from the roadside are also carried out.
i) The company should consider expanding the Journey Management plan to the
chemicals b usiness unit on a strategic b asis.
ii) Expand the ‘Target Zero’ safety awareness program, considered a b est practice
imported via the Tudhope Transport acquisition, to the Chemical Division and
potentially other transportation companies within the Seaboard/Harmac group.
iii) Complete linkages between the Transman system and the TWM dispatching computer
to prevent equipment from b eing dispatched when due for inspection and/or servicing.
iv) Anti roll over technology and anti under- run protection are best practices used on
petroleum units that the team suggests should b e selectively installed on chemical
trailers.
Bes t Practices:
The team found several examples of leading edge road transportation equipment, practices
and technologies in place or being implemented which it considered worthy of sharing with
CIAC peer com panies as follows:
i) The PeopleNet data management and On-Board Truck Computer (OBTC) systems that
record driving activity and allow for the use of e-mail communication, electronic driver
logs, incident flashes and truck operation analysis are an industry bes t practice.
ii) Tractors governed to 102 km/hr, both on pedal and cruise.
iii) The VORAD system for sensing blind spot encroachment.,
iv) The ‘Diesel Talk’ program, a motivational CD series, provides drivers with information
on transportation related health and safety issues.
v) The “pinging” back to dispatchers when posted driving speeds are being exceeded.
Page 16 of 28
vi) Well defined driver training program including the use of a well recognized driver
training process (Smith system) for initial, annual refresher and two year repeat driving
skills training.
Extra Mile:
i) The focus on technology to im prove road safety.
3b)
Supply Partner Assessments
The team looked at how customers, suppliers, carriers, contractors, etc. are assessed,
selected and measured for their performance with respect to meeting the Responsible
Care expectations of the company.
FINDINGS
Overview:
There is a formalized process for selection and approval of suppliers based upon quality of
work and materials supplied, and there is a preferred vendor list in place. New suppliers
are provided with information on Responsible Care and there is an annual review of their
performance.
Periodic audits of parts and equipment suppliers are carried out by fleet management
personnel to ensure company quality standards are met. Annual audits are also carried out
by fleet management personnel on external vehicle maintenance facilities. External tank
wash facilities are required to complete a self audit developed by the National Tank Truck
Carriers Cleaning Council, a program widely accepted throughout the industry. The
company’s commitment to Responsible Care is communicated to customers with an
expectation that they have process es in place to ensure the safety of personnel, product
quality and respect for the com pany’s equipment.
i) The company should consider doing a gap analysis b etween the audit/self assessment
processes used for each supplier and the applicable Responsib le Care elements and
codes and making the appropriate adjustments.
ii) Consideration should b e given to implementing a formal audit process to periodically
validate the quality/accuracy of self assessments.
3c)
Greenhouse Gas Emissions
The team looked at the company’s history, projections and plans for reducing greenhouse
gas emissions, both through reductions in direct emissions from facilities and equipment
and through energy efficiency/intensity improvements.
FINDINGS
Overview:
While greenhouse gas emission levels from road transport vehicles are regulated, the
company’s approach is to exceed the government standards wherever possible.
To this end a number of emissions reduction technologies have been implemented with
others being considered as they become available. Implemented examples include the
automatic shutdown of tractor engines after 5 minutes idling, bunk heaters in sleeper cabs
Page 17 of 28
to eliminate the need for running vehicle engines for heating, and power units being
governed to a maxim um speed of 102 KPH. New tractors are purchased with the latest
emission reducing technologies and the new driver scorecard system also focuses on
improving driving performance, which reduces environmental emissions.
i) Consider a greater focus on recycling of office materials. This is again an image that
needs to b e developed to reinforce the culture of responsib le management of
resources.
ii) Housekeeping - at b oth North York and the Burlington shops. Spillage b eside the waste
oil tank as an example at the Burlington site and just a general clutter at the shop in
North York. Allowing poor housekeeping habits does not support efforts when trying to
promote a no drip, no leak culture to drivers or mechanics that repair off-loading pumps.
iii) Waste containers for used oil or used cleaning chemicals should be labeled
appropriately. The message potentially received b y employees and drivers regarding
waste products not being taken could b e translated to driver conduct and attitude at
load points and customer delivery points.
iv) Include tire and waste oil recyclers in the supplier assessment process.
v) Add the condition of waste containers/tanks to Joint Health & Safety Committee
housekeeping checklists.
3d)
Security
The team looked at how the company assesses and manages potential security threats to
personnel, facilities, equipment, etc. throughout its entire transportation system (e.g.,
yards, terminals, routes, storage locations, etc.) including exposure to diversion of
materials for illicit activities such as use as or in production of chemical weapons,
explosives or narcotics.
FINDINGS
Overview:
There is a documented overall security plan in place, which includes a process to provide
all personnel with security awareness training. All drivers complete a test following the
training and they carry a card confirming that security training has been provided. Specific
policies also cover point-to-point cargo security; yards and facilities; equipment; and
internal activities. A sensitive information plan is communicated on a need to know basis
and reviewed annually.
The company is a certified and validated participant in “C-TPAT” a security initiative of the
U.S. Customs and Border Protection Agency. In 2005 the com pany’s security initiatives
were audited by the U.S. Department of Transportation acting on behalf of the U.S.
Department of Homeland Security.
Finding Requiring Action
i) Document, in the management system, the requirement to annually test through
an appropriate exercise, the effectiveness of the security management system
and its processes.
Page 18 of 28
Opportunity for Improvement
i) Expedite completion of the planned security assessment and appropriate security
upgrades at the newly acquired Burlington facility.
3e)
Emergency Response
The team looked at the company’s management system for ensuring appropriate
preparedness and response to emergencies throughout the entire transportation system
(e.g., yards, terminals, routes, storage locations, etc.), including involvem ent with local
emergency services and other mutual aid processes.
FINDINGS
Overview:
There is comprehensively documented emergency response plan in place, which is
designed to ensure an immediate and effective res ponse to operational emergencies. The
plan includes specific protocols for all facets of the business including petroleum, chemical
and compressed gases.
The worst case scenario for an incident at a com pany term inal, parking or other fixed
facility would be a failure of a full tank containing hazardous materials. This is mitigated by
a company policy and practice not to park full tanks on these premises. It is recognized
however that such parking situations could occur in exceptional circumstances, but every
effort is made to prevent this from occurring.
Specialised services are contracted to carry out product handling during an emergency,
and the company takes responsibility for clean-up and remediation activities, where this is
required.
The emergency manual has been shared with a number of the company’s core customers
which have multiple sites serviced by the organization.
Finding Requiring Action
i) Document the requirement for, and implement, an annual emergency exercise
program to validate and maintain the effectiveness of the emergency exercise
management system and its processes.
Opportunities for Improvement
i) The emergency response plan should include the requirement for a periodic review of
the potential impacts of neighbour operations on company owned facilities.
ii) Update the emergency response manual for contact names and phone numb ers. In the
customer contact section there was a least one company and contact that no longer is
correct – for at least the last 7-8 years.
iii) Include local emergency responders in terminal response exercises for scenarios where
there is a potential for their participation.
3f)
TransCAER Outreach/Community Dialogue
The team looked at how the company is fulfilling it’s commitments for ensuring the
potentially affected public understands and are prepared for the risks presented by
adjacent transportation operations, including outreach and two way dialogue initiatives .
Page 19 of 28
FINDINGS
Overview:
The company is represented on three (3) CIAC Trans CAER committees. Thes e are
Toronto, Ontario Regional and National. Involvem ent with the Quebec Regional
TransCAER Committee continues to be sought. Company TransCAER representatives
generally attend the required local and regional TransCAER meetings and there appears to
be the requisite participation in TransCAER activities. TransCAER events in which the
company has participated during the past year included an equipment demonstration by
the Toronto Fire Department, a mock exercise led by the city of London and an equipment
demonstration as part of the Sarnia area Community Ad vis ory Panel (CAP) in Ma y, 2010.
There has been no significant change in concerns expressed by the public since the last
verification. These primarily take the form of complaints about the manner in which they
have observed company trucks operating on the highway. All complaints of this nature are
followed up with the driver concerned and the complainant where information is provided to
identify the individuals.
The company is a member of the Emery Village Business Improvement Area (BIA) in
North York. The local community representative on the verification team is an employee of
the BIA.
Opportunities for Improvement
i) The company should estab lish an ongoing association with the BIA through the local
community representative to facilitate communication with the local community.
ii) At the Burlington facility, the company should consider periodic visits with the facility’s
neighb ours as a means of keeping ab reast of changes to operations adjacent to the
facility and to exchange operational risk information.
iii) Community communications and neighbor visits should be recorded/logged to help
identify the effort with the comm unication whether it was successful or not.
iv) Create a layman’s summary of this re-verification report for sharing with their BIA and
follow-up with this organization on how it was distributed and received.
3g)
Social Responsibility/Sustainability
As a separate task from the re-verification process, the verifiers have been requested to
collect information on:
- How the company sees and fulfills its role in areas of social responsibility and
- What, if anything, the company has considered doing, or may have started to do,
opposite the new Responsible Care® Ethic & Principles for Sustainability.
In these areas, the team was not looking for evidence that the company’s performance met
certain expectations, but rather for information on how the company sees and fulfills its role
in these areas. This information may prove us eful as CIAC works to update the Codes of
Practice, guidance material and Re-verification Protocol for Transportation Partners.
Verifiers have not judged the answers, and the company was not expected to have
answers for all or any of thes e questions. Information provided on social responsibility is
detailed below while
Page 20 of 28
FINDINGS
Social Responsibility
The company recognizes that their success requires engaging employees that have an
understanding, and appreciation for the direction and culture of the company. Inherent in
this culture is the intent to create a better life for its employees and a responsibility to the
broader society.
Social responsibility is recognized, encouraged and supported through a number of
initiatives. The company newsletter includes a section called “Seaboard/Harmac giving
back to the community”. This highlights community spirit stories of friends and co-workers
that volunteer their skills, time and efforts to support local communities. The company also
runs a number of programs that enhance the lives of their employees and the surrounding
community. Som e of these are:
- Annual food drive
- Support for the Salvation Army
- Support for sleep apnea testing
- Participation in the Sarnia Transportation CAP community outreach program
- Educational assistance plan for employees
Principles for Sustainability
The company has provided answers to questions on the Principles for Sustainability which
are detailed on attachment 3 of this report.
4.
CONCLUSION
As a result of the various site vis its, documentation reviews and several interviews with
company personnel and external stakeholders, the re-verification team is satisfied that the
company’s decision-making and actions are underpinned by the Responsible Care ethic,
and that the overall management system is self-healing (i.e., based on a process of
continual performance improvement, and identification and timely correction of
deficiencies). This was also demonstrated by the clear commitment of com pany pers onnel
to do the right thing and do it well. The team believes that the company is capable of
responding to the Findings Requiring Action identified during this re-verification. The reverification is complete and no further involvem ent is required by the re-verification team .
5.
COMPANY COMMENTS
Harmac Transportation and its representatives would like to thank the re-verification team
for a comprehensive, insightful and efficient re-verification process.
Harmac is in agreement with the Findings and Opportunities for Improvem ent (OFI)
identified within and appreciate the efforts of all in capturing these for constructive follow up
and continuous improvement.
The process from here will be to reconvene as a Responsible Care leadership group (core
and extended team members) and set out a plan to address the findings and prioritized
OFI’s.
Page 21 of 28
Harmac looks forward to the development of the new Transportation Partner Protocol and
would be happy to ass ist in anyway needed.
Thanks to the re-verification team again for a successful process.
David MacDonald
Vice President- Chemicals & Business Development, CIAC Executive Contact
Page 22 of 28
APPENDIX 1
COMPANY DESCRIPTION
Harmac Transportation Inc. is a 100% owned subsidiary of Seaboard Liquid Carriers
headquartered in Dartmouth, Nova Scotia.
Since the previous Re-verification in 2006, the company has continued to be active in three
major bulk liquid divis ions (petroleum, liquid chemical and LPG). Core products moved in
the liquid/chemical divis ion include soaps, resins, latex, oil, chlorine and solvents. The
petroleum division transports gasoline, diesel fuel, jet fuel and naphtha. However, there
have been significant organizational and operations scope changes since the previous Reverification as follows:





The Seaboard corporate structure has been changed from regional specific to business
specific profit centres. There are now two Operations Vice Presidents, one for
petroleum and LPG, including these areas of Harmac, and a second for Chemical
liquids and Business Development. The Chemical liquids and Business Development
VP, David MacDonald, joined the company in September, 2010, and has subsequently
assumed the role of CIAC’s Executive Contact from Seaboard’s President, Mark
Shannon. David brings chemicals industry experience to his new role, having previously
been employed by a major Canadian chemicals manufacturer.
In 2006, the company acquired AJ Weigand, a chemical liquid carrier based in Bolivar,
Ohio with satellite operations in Duncan, South Carolina. This operation runs 45 units
domestically in the US and cross border into Canada.
In April, 2010, a modern terminal and maintenance facility in Burlington, previously
owned by a flat deck carrier, was acquired and is currently being used as a base for
LPG operations and to augment corporate fleet maintenance capabilities in the central
Ontario area.
Petroleum operations have recently expanded with the purchase of Mantei’s Transport,
an Alberta based carrier with terminals in Calgary and Edmonton.
The scope of chemicals operations has been scaled down in response to the economic
downturn. One outcome of this is that Sarnia operations have been scaled back from a
full terminal, maintenance facility to a maintenance shop/ equipment holding yard
status. The number of tractors in the Canadian liquid/chemical divis ion has also been
reduced from 112 to 87 while the petroleum fleet has increased from 72 to 126.
All Harm ac facilities and operational infrastructure in Canada are subject to the
Responsible Care commitment. These include the following:




North York office, term inal and garage operations.
Montreal office, terminal and garage operations
Sarnia garage operations.
Burlington office, terminal and garage operations.
Page 23 of 28
APPENDIX 2
TEAM AND CONTACTS
1.
The Verification Team
The verification team consisted of the following:
Name
Affiliation
Alec Robertson
Consultant
Claude Bourdon
Consultant
Jim Wakefield
General Public
Christina Sulmona
Emery Village Business Association
Team members assigned by CCPA are shown by an asterisk (*).
Representing
Industry (team leader)*
Industry*
Public*
Community
2.
Persons contacted at the company
Name
Position
David MacDonald
Vice President- Chemicals & Business Development, CIAC
Executive Contact
Bob MacQuarrie
Vice President-Energy & Refined Products
Harv Roberts
Director, HSE-Seaboard Transport
Albert Cos ta
Divis ion Manager- Liquid Chemicals
Mark Napier
Regional Operations Manager-Ontario
Todd Stauffer
General Manager-Branded Companies
Scott Mannett
Operations Manager-Liquid Chemicals
Brad Beaton
Manager-National Compliance
Barry Briggs
Manager-Health, Safety & Compliance, Central Region
Mike Sharpe
Quality Assurance Manager
Craig Whittaker
Process Improvem ent Manager
Jeff Waite
HSE Compliance Management
Darrell MacNeil
Garage Manager – Fleet Solutions
Garry Stewart
Shop Manager-North York & Burlington
Gerald Stephens
L.P.G. Operations-Burlington
3.
Process for obtaining information
The process followed the CCPA Responsible Care Re-verification Protocol (2006-2008) for
Transportation Partners, and consisted of a series of interviews with management, support
staff and hands on employees, document reviews, and site inspections.
Vis its were made to the company head office/transportation terminal in North York and the
transportation terminal in Burlington, Ontario.
Page 24 of 28
APPENDIX 3
FACT-FINDING QUESTIONS
RE NEW RESPONSIBLE CARE ETHIC & PRINCIPLES FOR SUSTAINABILITY
“Describe any new things you, at the site and/or corporate level, have considered,
are doing or have started to do with respect to these concepts:

Work for the im provement of people’s lives .
i) Speed management
ii) Fatigue management programs
iii) Driver behavioral programs being introduced
iv) Sleep apnea program being reviewed

Work for the im provement of the environment.
i) Speed management process- Truck speed is governed and monitored
ii) Idling time management process - Truck has maximum idle time shut off and
monitored
iii) Side shields for wind deflection on van trailers
iv) Installation of bunk heaters in tractors to prevent winter idling

Take preventative action to protect health and the environment.
i) New tractor purchases – reduced emission technology

Innovate for safer products.
i) Anti roll over technology has become standard equipment on all new petroleum
equipment
ii) Under run protection on petroleum equipment
iii) Battery em ergency dis connect on tractors
iv) Better view points for driver vis ibility being incorporated into truck specification

Innovate for safer processes.
i) Mandating the corporate introduction and support to on board computer –
PeopleNet

Innovate to cons erve resources.
i) Recap in fleet tire program
ii) Used oil recovery and sold to industry process companies
iii) Seasonal control over exterior lighting

Innovate for products and processes that provide enhanced value.
i) No offers

Engage with business partners to ensure stewardship and security of products and/or
services.
i) working with customer for increased use of sealed product
ii) working with customers and consignees in developing route assessments
Page 25 of 28

Engage with business partners to ensure stewardship and security of raw materials.
i) Pail off of residual petroleum products at loading terminal
ii) Transport of co mingle products back to origin for the re refinement of the
products

Understand and meet expectations for social responsibility.
i) looking at integrating social responsibility as part of the driver outreach meetings
ii) looking at a quarterly R.C. leadership round table

Promote awareness of Responsible Care.
i) Website
ii) Company letterhead
iii) Employee orientation new and exis ting
iv) TransCaer
v) Marketing literature
vi) Office vis uals (plaque, banners etc.)
Page 26 of 28
APPENDIX 4
SUMMARY OF OPPORTUNITIES FOR IMPROVEMENT
1) Ensure that all opportunities for improvement identified in the 2006 re-verification report
have b een appropriately considered and addressed with the results documented.
2) Add Responsible Care signage (e.g. external banners and/or flags) to assist in b randing
Responsible Care in the community.
3) Consider migrating Responsible Care to the rest of the transportation companies within
the Seaboard/Harmac group - Seab oard, GWR, Foss and the US com pany – AJ
Weigand b y ensuring and communicating that, while it is a CIAC initiative to which
Harmac formally sub scribes, the ethic, principles and expectations are sub scribed to
throughout Seaboard and reflected in processes in place throughout the company.
4) Communicate this re-verification report to the North York community through the local
Business Improvement Area (BIA) organization.
5) Document employee Responsib le Care training/retraining expectations and include in
the training management system .
6) With Responsib le Care being first and foremost an ethic, not a program (often displayed
as an umb rella), this should be communicated at the b eginning of the management
systems document. Responsible Care specifics could b e further described with other
programs or processes in place elsewhere in this document.
7) Document Responsible Care responsibilities in appropriate employee job descriptions.
8) The Team suggests that Harmac’s management of change process includes
organizational changes for positions with Responsib le Care responsibilities.
9) Include Responsible Care expectations in the assessment process for potential new
customers.
10)The company should ensure that the safety database reflects the final disposition and
closure of all incidents and concerns that have b een reported into the database
including those that have been handed off to other control system s for resolution.
11)Harmac are encouraged to continue their initiative to identify and implement
improvement initiatives to reduce product handling incident rates.
12)There is an opportunity for the company to complete the linkage of driver scorecard
performance to the form al performance evaluation process and driver b onus program
across all divisions.
13)Identify and implement a consistent driver incentive program for the entire organization,
specifically across the different operating companies.
14)There is an opportunity for the company to develop a formalized industry performance
benchmark process with performance targets established for various identified
measurement areas.
15)Add additional b road b ased indicators to the current slate of performance measures.
(e.g. completion of planned events and activities such as for TransCAER, emergency
response drills, and outreach; and tracking of public concerns received).
16)The company should consider expanding the Journey Management plan to the
chemicals b usiness unit on a strategic b asis.
17)Expand the ‘Target Zero’ safety awareness program, considered a b est practice
imported via the Tudhope Transport acquisition, to the Chemical Division and
potentially other transportation companies within the Seaboard/Harmac group.
18)Complete linkages between the Transman system and the TWM dispatching computer
to prevent equipment from b eing dispatched when due for inspection and/or servicing.
Page 27 of 28
19)Anti roll over technology and anti under- run protection are best practices used on
petroleum units that the team suggests should b e selectively installed on chemical
trailers.
20)The company should consider doing a gap analysis b etween the audit/self assessment
processes used for each supplier and the applicable Responsib le Care elements and
codes and making the appropriate adjustments.
21)Consideration should be given to implementing a form al audit process to periodically
validate the quality/accuracy of self assessments.
22)Consider a greater focus on recycling of office materials. This is again an image that
needs to b e developed to reinforce the culture of responsib le management of
resources.
23)Housekeeping - at b oth North York and the Burlington shops. Spillage b eside the waste
oil tank as an example at the Burlington site and just a general clutter at the shop in
North York. Allowing poor housekeeping habits does not support efforts when trying to
promote a no drip, no leak culture to drivers or mechanics that repair off-loading pumps.
24)Waste containers for used oil or used cleaning chemicals should be labeled
appropriately. The message potentially received b y employees and drivers regarding
waste products not being taken could b e translated to driver conduct and attitude at
load points and customer delivery points.
25)Include tire and waste oil recyclers in the supplier assessment process.
26)Add the condition of waste containers/tanks to Joint Health & Safety Committee
housekeeping checklists.
27)Expedite completion of the planned security assessment and appropriate security
upgrades at the newly acquired Burlington facility.
28)The emergency response plan should include the requirement for a periodic review of
the potential impacts of neighbour operations on company owned facilities.
29)Update the emergency response manual for contact names and phone numb ers. In the
customer contact section there was a least one company and contact that no longer is
correct – for at least the last 7-8 years.
30)Include local emergency responders in terminal response exercises for scenarios where
there is a potential for their participation.
31)The company should estab lish an ongoing association with the BIA through the local
community representative to facilitate communication with the local community.
32)At the Burlington facility, the company should consider periodic visits with the facility’s
neighb ours as a means of keeping ab reast of changes to operations adjacent to the
facility and to exchange operational risk information.
33)Community communications and neighbor visits should be recorded/logged to help
identify the effort with the comm unication whether it was successful or not.
34)Create a layman’s summary of this re-verification report for sharing with their BIA and
follow-up with this organization on how it was distributed and received.
Page 28 of 28
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

responsible care - Chemistry Industry Association of Canada

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