RESPONSIBLE CARE® Verification Report Imperial Oil - Chemicals February 22 - 23, 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.
CONTENTS
EXECUTIVE SUMMARY 3 Summary of Verification Team Observations 4 Findings Requiring Action 4 Improvement Opportunities 4 Successful Practices 6 1. Introduction 7 1.1 About Responsible Care Verification 7 1.2 About Imperial Oil Chemicals (IOC) 8 1.3 About This Verification 9 2. Team Observations Concerning the Responsible Care Commitments (Codes and benchmark and Collective Expectations) 11 2.1Team Observations Concerning Operations Code 12 2.2 Team Observations Concerning Stewardship Code 15 2.3 Team Observations Concerning Accountability Code 16 3. Team Observations on the Company Management System 18 3.1 Observations on the PLAN step 18 3.2 Observations on the DO Step 19 3.3 Observations on the CHECK Step 19 3.4 Observations on the ACT Step 20 4. Team Observations on the Responsible Care Ethic and Principles for Sustainability 21 5.Verification Team Conclusion 21 Attachment 1: Company Response to Verification Team Report 22 Attachment 2: Interview Lists 23 A: Company Personnel Contacted During Verification Process 23
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 2 EXECUTIVE SUMMARY This report documents the observations and conclusions of the independent verification team tasked with conducting a Responsible Care Verification of Imperial Oil Chemicals (IOC). The verification began with a visit to their Calgary headquarters on December 13, 2010, with the visit to their Sarnia operations site, scheduled for the following two days, delayed due to weather related travel restrictions until February 22 and 23, 2011. The verification team also conducted interviews with other company personnel via telephone. This was the fifth Responsible Care verification completed for IOC with the previous verification being completed in June 2007.
While considering all aspects of the Responsible Care Commitments during this verification the team placed an emphasis on conducting an in-depth examination of company aspects related to the 2009 Responsible Care Protocol: Overall Responsible Care Management Occupational Health and Safety System Transportation Security Response to Incidents and Concerns Risk Communication Performance Measures Social Responsibility Process Safety Management TransCAER outreach Product Stewardship Carrier Selection Site Security and Emergency Response Engagement of Elected Officials Environmental Management Community Outreach and Dialogue Visibility and Employee Awareness of Responsible Care
As a result of the examination conducted, the verification team is of the opinion that the Responsible Care Ethic and Principles for Sustainability are guiding Imperial Oil Chemicals 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 single Finding Requiring Action identified during the verification: summarized below and discussed in detail in the report. The verification is complete and no further involvement is required by the verification team.
Signed: Date: 27 April, 2011 Gerry Whitcombe 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 overall Responsible Care coordinator: Peter Forristal (403)237-4149 Peter.M.Forristal@esso.ca
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 3 SUMMARY OF VERIFICATION TEAM OBSERVATIONS
Finding Requiring Action
1. There is a Finding Requiring Action in respect of code element ST116. This element requires companies to ensure service providers meet the same expectations as if the company were performing the activities itself. The team felt aspects relating to communications of hazards and risks present at terminals were not well implemented and the management system for third party contractors should be modified to reflect the requirements of this element. 15
Work in Progress
1. The team acknowledges as a work in progress the company’s identification of the requirement for broader application of ST115-ST124. In particular, the team encourages the company to practice due diligence in ensuring that the operators of pipelines used to transport company material are aware of and adhere to the principles and codes of Responsible Care. 13
2. The team acknowledges the company has identified the promotion of Responsible Care by name to company employees, and other stakeholders as a gap in its implementation. This is a work in progress that the team suggests be reviewed during the next verification. 14
Improvement Opportunities
1. There is an Improvement Opportunity to review the Responsible Care re-verification report of CIAC-Transportation-Partners and work with the Partners to identify and act on documented findings and opportunities for improvement (OP13). 12
2. The company uses trend analyses of its extensive suite of leading (and lagging) indicators to identify areas which may lead to reductions in incidents and injuries. One program coming from this process, developed with the involvement of the JH&SC, was a renewed emphasis on off-the- job safety. This is an excellent initiative from several perspectives and the team feels there is an Improvement Opportunity to make the program more effective by using the company’s knowledge and experience to incorporate an instructional element into the plan. 13
3. There is an Improvement Opportunity to link changes as the result of reassessments of Worst Case or Worst Credible Case Scenarios to the community communication process and literature. 13 4. There is an Improvement Opportunity for external communication activities warranted by a site emergency to ensure, through testing of the communication plan, testing of the integration of
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 4 the emergency plan with the communications plan or follow up to an unplanned event, that public expectations are being met, particularly during the unfolding of the event. 13
5. The EEE program was indeed excellent and the team felt there was an Improvement Opportunity to bring this training to all Imperial Oil employees whose job may have an impact on the environment. 14
6. The team felt the company has an Improvement Opportunity to environmentally enhance vacant properties in and around its Sarnia site by limiting emissions from such activities as lawn cutting and trimming and instead planting native grasses, trees and wild flowers. 14
7. There is an Improvement Opportunity to formalize the assessment process for service providers where company product is held, (for example, but not limited to tollers and terminals) (ST118). 16
8. With regard to the Best Practice for External Affairs, the team felt an Improvement Opportunity would be to advocate for wording changes to more accurately reflect the purpose of the program, and lessen the appearance of the plan being a public relations exercise. 16
9. There is an Improvement Opportunity for the company to provide leadership to develop, in concert with other member companies, a process allowing the CAER committee to better understand and satisfy community communication needs by utilizing the BCAP. 16
10. There is an Improvement Opportunity in the management system for community dialogue to review Accountability Code elements AC125-AC127. Please refer to the list of suggestions that follow. 17
11. The site issues a community newsletter, “Neighbour News’, which includes a three year emissions reporting component. There is an Improvement Opportunity in the comments section to provide comments relevant to the statistics and years being reported and refrain from simply making statements that cast a positive light on the company and deflect attention away from the statistics being presented. 17
12. Broader exposure of this fact sheet to CIAC members would be beneficial and the team believes an Opportunity for Improvement would be for the company to submitted a template of the sheet to the CIAC library for members use. 17
13. There is an Improvement Opportunity to include radio station call letters and frequencies in community fact sheets. 17
14. There is an Improvement Opportunity to ensure aspects related to TransCAER job scope, process, roles and responsibilities are defined, documented and transferred during the management of people change process. 17
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 5 Successful Practices
1. Collectively the Buddy Manager Program (BMP), Bud Lite Program and Short Service Workers Program, with their particular requirements and accountabilities consitute a Successful Practice for management of and continuous improvement in the company’s Contractor Management program. 12
2. The Process Safety Group manages a program coordinating the company’s key risk programs. This involves 11 separate risk discovery processes and this approach to understanding the issues and coordinating the effort is innovative and, in the team’s opinion, a successful practice.13 3. The company has developed a process safety training course. The team believes the concept of a layman’s approach to a very technical topic is worthy of sharing as a Successful Practice.13
4. The company’s “Essentials of Environmental Excellence” (EEE) training of leaders with its twelve step journey is a Successful Practice. The EEE training attempts to make environmental performance a personal commitment just as safety is a personal commitment for all employees and contractors. 14
5. The structured approach and resulting discipline present in the “Environmental Business Planning” (EBP) process is a Successful Practice in integrating environmental considerations into business strategies and plans. 14 6. The team felt that the potential for greatly increasing the ability to detect leaks by the use of infrared camera technology, although still under investigation, warranted a Successful Practice. 14
7. The team felt the Best Practice for External Affairs (BPEA), by drawing together all the various stakeholders under one plan and defining the specific communication activities, goals and responsibilities assigned to each group based on their specific communication needs is a Successful Practice. 16
8. The company’s Operations Integrity Management System (OIMS) with its direct management by the company’s Operations Integrity Steering Committee is an example of a Successful Practice. OIMS is a sophisticated and durable managing system which allows for the successful integration and implementation of the Responsible Care Codes of Practice. 18
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 6 1. INTRODUCTION 1.1 About Responsible Care Verification
As a member of the Chemistry Industry Association of Canada (CIAC),the most senior executive responsible for IOC’s operations in Canada attests annually to CIAC and its peers that the company’s operations conform to the expectations contained in the Responsible Care Commitments and are guided by Responsible Care Ethic and Principles for Sustainability.
The Responsible Care® Ethic and Principles for Sustainability
We are committed to do the right thing, and be seen to do the right thing.
We dedicate ourselves, our technology and our business practices to sustainability - the betterment of society, the environment and the economy. The principles of Responsible Care® are key to our business success, and compel us to:
• work for the improvement of people's lives and the environment, while striving to do no harm; • be accountable and responsive to the public, especially our local communities, who have the right to understand the risks and benefits of what we do; • take preventative action to protect health and the environment; • innovate for safer products and processes that conserve resources and provide enhanced value; • engage with our business partners to ensure the stewardship and security of our products, services and raw materials throughout their life-cycles; • understand and meet expectations for social responsibility; • work with all stakeholders for public policy and standards that enhance sustainability, act to advance legal requirements and meet or exceed their letter and spirit; • promote awareness of Responsible Care, and inspire others to commit to these principles.
As an element of this commitment to Responsible Care, IOC must, every three years, participate in an external verification intended to:
1. Provide the Executive Contact with an external perspective when assessing if the company is indeed meeting the intent of the Responsible Care Commitments, along with advice on areas that may require attention; 2. Identify opportunities for assisting the company when benchmarking its own practices and performance against those of its peers, thus supporting continual improvement;
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 7 3. Contribute to the credibility of Responsible Care amongst company personnel and stakeholders, as well as the stakeholders of the broader industry; 4. Identify successful company practices that can be promoted to peers in the CIAC membership; and 5. Support the identification of areas of common weakness so that collective tools and guidance can be developed to improve performance in those areas across the CIAC membership.
Verification is conducted according to a common protocol, developed by the association’s members and others, including several critics of the chemical industry. The 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 Advisory Panel) and • One or more representatives of the local communities where the company’s facilities are located.
Once completed, the Verification Report is made publicly available through the CIAC website (www.canadianchemsitry.ca). IOC is also expected to share the report with interested persons in its communities and other stakeholders as part of its ongoing dialogue processes.
Additional information on Responsible Care and / or the verification process can be found at the CIAC website www.canadianchemistry.ca, or by contacting the Responsible Care staff at CIAC at [email protected] or (613) 237-6215 extension 233.
1.2 About Imperial Oil Chemicals (IOC)
Imperial Oil Chemicals, headquartered in Calgary, is a division of Imperial Oil Limited and is a major producer and seller of petrochemicals, ranging from primary petrochemicals to plastic resins and aliphatic and aromatic solvents.
Exxon Mobil Corporation is the major shareholder of Imperial Oil Ltd., having an equity position of 69.6 %, unchanged for more than a century. The balance of the ownership is widely dispersed and held by minority shareholders. Imperial Oil is self-financing and governance is provided by a Canadian board of directors, consisting of five non-employee directors and four employee directors.
As an affiliate of Exxon Mobil Corporation, IOC has access to Exxon Mobil Research and Development (R&D) for both processes and products. Imperial and Exxon Mobil also operate an employee interchange program to provide relevant technical and management development opportunities.
Imperial's chemicals business is managed within the Products (petroleum) & Chemicals Division, with a senior executive - the Manager of Imperial Oil Petrochemicals, reporting
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 8 directly to Imperial Oil’s Chairman, President and Chief Executive Officer. Imperial Oil, at a corporate level, develops and maintains up-to-date key policies for which all employees, associates, suppliers, and contractors are expected to follow.
The Manager of Petrochemicals has full accountability for all elements of the chemicals business. He is the CIAC signing executive and is fully responsible for the company’s commitment to Responsible Care.
Most of IOC’s principal functions (i.e. production, sales, and business development) are structured within an organization reporting to the Manager of Petrochemicals. IOC also receives services from other functional organizational units within Imperial -- such as distribution, public affairs, materials procurement, legal, medical, and accounting.
IOC has three main business entities: Basic Chemicals, Intermediates (solvents, fluids) and Polymers. The chemical production units are located at one large, multi-unit manufacturing site in Sarnia that produces approximately 0.7 million tonnes per year of chemical, fuel and lubricant products. Feedstocks are obtained from externally purchased sources and from intermediate (petroleum) refinery streams at the site, principally light hydr ocarbons (ethane, propane, butanes, propylenes, butylenes and naphthas).
Sarnia-produced chemical products are sold both domestically in all parts of Canada and internationally (primarily USA) using rail, truck and marine modes of transportation, with rail and truck the dominant modes
Additionally, the direct chemicals sales organization manages the sale of some Exxon Mobil chemical product lines to Canadian customers, such as the additives to soften plastics. It also manages the direct sales function of domestically produced chemicals to customers in the United States through its CIOL subsidiary (Canada Imperial Oil Limited).
The company owns and operates a bulk terminal and warehouse at its Sarnia site and contracts a warehouse in Mississauga ON Its two principal motor carriers are located in Sarnia ON. In addition the company externally contracts a bulk terminal operation in Hamilton ON, plastic grinding and packaging operations in Brantford ON and Calgary AB and plastic packaging only in Corunna, ON.
For more information on Imperial Oil Chemicals and links to Imperial Oil please see: http://www.imperialoil.com/Canada-English/products_chemical.aspx
1.3 About This Verification
The verification of IOC began with a visit to their Calgary headquarters on December 13, 2010, with the visit to their Sarnia operations site, scheduled for the following two days, delayed due to weather related travel restrictions until February 22 and 23, 2011. The verification team also conducted interviews with other company personnel via telephone. During the course of the
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 9 verification, the team had the opportunity to interact with a wide range of company personnel. Attachment 2 contains a list of those individuals interviewed and their affiliations. This was the fifth Responsible Care verification completed for IOC with the previous verification being completed in June 2007.
The verification team was comprised of the following individuals. Gerry Whitcombe (Team Leader) Alec Robertson (Industry verifier) Jim Wakefield (Public-At-Large Verifier) Brenda Lorenz (Community Representative – member of the Bluewater Community Advisory Panel (BCAP), Sarnia, ON)
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 10 2. TEAM OBSERVATIONS CONCERNING THE RESPONSIBLE CARE COMMITMENTS (CODES AND BENCHMARK AND COLLECTIVE EXPECTATIONS) During the verification of IOC, the verification team looked for evidence that the company was addressing the expectations documented in the Responsible Care Commitments (152 code elements plus 28 benchmark and collective expectations). While considering all aspects of the Responsible Care Commitments during the verification, the team placed an emphasis on conducting a more in- depth examination of certain company aspects related to the 2009 Responsible Care Protocol: Overall Responsible Care Management Occupational Health and Safety System Transportation Security Response to Incidents and Concerns Risk Communication Performance Measures Social Responsibility Process Safety Management TransCAER outreach Product Stewardship Carrier Selection Site Security and Emergency Response Engagement of Elected Officials Environmental Management Community Outreach and Dialogue Visibility and Employee Awareness of Responsible Care In communicating its observations, the verification team will make repeated reference to the following categories of observations:
1. Findings Requiring Action document instances where the verification team observes specific company actions (or the absence of company actions) which are inconsistent with the detailed codes and benchmark and collective expectations contained in the Responsible Care Commitments. Where possible, the verification team will communicate, based on their experience and judgment, why it is inconsistent and how the observation relates back to a possible gap in the expected management system and / or the ethic and principles underpinning company actions. The team may also provide advice on how the situation might be responded to.
2. Works in Progress document instances where the verification team has observed the company self- initiating actions in response to identified gaps and deficiencies arising from other internal or external audit and review activities, or where the company has self-initiated important improvement opportunities.
3. Successful Practices document instances where the team believes the company has taken actions that strongly support sustained excellence in performance, and which should be communicated throughout the CIAC membership.
4. Improvement opportunities identify instances where the verification team has observed company actions and decision making as being largely consistent with the expectations detailed in the
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 11 Responsible Care Commitments, but for which the team is of the opinion that the company could support further improvement by considering alternate or additional benchmarks when undertaking its planning and decision making.
The verification team’s observations of how the company has addressed the Responsible Care Commitments are as follows:
2.1 Team Observations Concerning Operations Code
2.1.2 Operations Activities
Transportation and Physical Distribution.
The team reviewed all elements of this sub-section (OP 12 -OP16) and generally found implementation to be exceeding expectations.
The company’s motor carrier management system is impressive for its comprehensiveness in the carrier selection and assessment process, as well as the assessment of carrier performance and tracking of leading indicators.
There is an Improvement Opportunity to review the Responsible Care re-verification report of CIAC-Transportation-Partners and work with the Partners to identify and act on documented findings and opportunities for impro vement (OP13).
2.1.3 Safety and Security
The team interviewed employees and reviewed documentation related to 5 of the 6 sub- sections of this code section, excluding Resource Conservation. In each case the team found that the detailed Responsible Care code element requirements had been mapped into the company’s formal management systems and was being implemented in a manner generally exceeding expectations.
Key verification team observations related to three of these sub-sections are as follows:
Occupational Health and Safety
All six elements of this code sub-section were reviewed (OP22-OP27).
Collectively the Buddy Manager Program (BMP), Bud Lite Program and Short Service Workers Program, with their particular requirements and accountabilities constitute a Successful Practice for management of and continuous improvement in the company’s Contractor Management program.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 12 The team was impressed at the frequency in which a “Cold Eye Review” process is used. This includes the objective review of work by a knowledgeable person who is not directly involved in the work, allowing for out-of-the box thinking.
The company uses trend analyses of its extensive suite of leading (and lagging) indicators to identify areas which may lead to reductions in incidents and injuries. One program coming from this process, developed with the involvement of the JH&SC, was a renewed emphasis on off-the-job safety. This is an excellent initiative from several perspectives and the team feels there is an Improvement Opportunity to make the program more effective by using the company’s knowledge and experience to incorporate an instructional element into the plan.
Process Safety Management
All three elements of this code sub-section were reviewed (OP28-OP30).
The Process Safety Group manages a program coordinating the company’s key risk programs. This involves 11 separate risk discovery processes and this approach to understanding the issues and coordinating the effort is innovative and, in the team’s opinion, a successful practice.
The company has developed a process safety training course. The team believes the concept of a layman’s approach to a very technical topic is worthy of sharing as a Successful Practice.
There is an Improvement Opportunity to link changes as the result of reassessments of Worst Case or Worst Credible Case Scenarios to the community communication process and literature.
The team observed that pipeline operators handling company material have not been made aware of, nor are held accountable to the principles and codes of Responsible Care. The company has identified this in their gap analysis for the new Codes of Practice as a potential gap.
The team acknowledges as a work in progress the company’s identification of the requirement for broader application of ST115-ST124. In particular, the team encourages the company to practice due diligence in ensuring that the operators of pipelines used to transport company material are aware of and adhere to the principles and codes of Responsible Care.
Emergency Management
Only site emergency management elements (OP31-OP40) were reviewed in this sub -section.
There is an Improvement Opportunity for external communication activities warranted by a site emergency to ensure, through testing of the communication plan, testing of the integration of the emergency plan with the communications plan or follow up to an unplanned event, that public expectations are being met, particularly during the unfolding of the event.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 13 2.1.4 Environmental Protection
The team conducted interviews and reviewed documentation at both the Calgary headquarters and the Sarnia site. Only the first sub-section (Emissions and Waste Reduction – (OP 59 -OP63)) of this area was reviewed in detail and was found to be mapped into the company’s management systems and has been implemented generally exceeding Responsible Care expectations.
Emission and Waste Reduction
The company’s “Essentials of Environmental Excellence” (EEE) training of leaders with its twelve step journey is a Successful Practice. The EEE training attempts to make environmental performance a personal commitment just as safety is a personal commitment for all employees and contractors.
The EEE program was indeed excellent and the team felt there was an Improvement Opportunity to bring this training to all Imperial Oil employees whose job may have an impact on the environment.
The structured approach and resulting discipline present in the “Environmental Business Planning” (EBP) process is a Successful Practice in integrating environmental considerations into business strategies and plans.
The team felt the company has an Improvement Opportunity to environmentally enhance vacant properties in and around its Sarnia site by limiting emissions from such activities as lawn cutting and trimming and instead planting native grasses, trees and wild flowers.
The team felt that the potential for greatly increasing the ability to detect leaks by the use of infrared camera technology, although still under investigation, warranted a Successful Practice.
2.1.6 Promotion of R esponsible Care by Nam e
It is the opinion of the team that the company is only be ginning to promote Responsible Care by name, especially to its own employees. The main reason is because its Operations Integrity Management System (OIMS) is the vehicle by which almost all Responsible Care requirements have been implemented and the company does not wish to confuse employees by having them understand a parallel structure.
The company has recognized this shortfall which it has documented in its gap analysis.
The team acknowledges the company has identified the promotion of Responsible Care by name to company employees, and other stakeholders as a gap in its implementation. This is a work in progress that the team suggests be reviewed during the next verification.
A few examples of where this may be possible are:
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 14 Promote Responsible Care by name in all CEO monthly employee meetings
Initial and on-going Responsible Care training exposure for all employees and contractors
Encourage leaders to make others aware of IOC’s willingness to share information which will help improve benchmarking and Responsible Care performance
Make Responsible Care a part of the Management of People Change process, where appropriate, for employees who move to new job functions
Increased usage of Responsible Care promotional posters and banners
Formally incorporate the Responsible Care ethic and principles into contractor screening
Promote Responsible Care by name during Tech Service visits to customers 2.2 Team Observations Concerning Stewardship Code
This re-veri fication was conducted using the 2009 Protocol and was limited in its opportunities to investigate, in detail, some of the new or restructured aspects of product stewardship
The company has completed its gap analysis of the new codes and has identified potential gaps in this area which the team feels should be part of the focus of the next re-verification.
2.2.1 Expectations of Companies
Research and Development (R&D) Expectations
Interviews were held with R&D and the team reviewed their stage gate process, which is used to manage the company’s R&D activities. The team feels this is a sound technical basis for this aspect of stewardship.
The principle team focus was on R&D management systems and observations are included in section 3 of this report.
2.2.2 Expectations with Respect to Other Parties
The team reviewed the company’s programs for managing Responsible Care at companies who provide services to the company.
In general the company has implemented code requirements meeting expectations as defined in the 2009 Protocol.
There is a Finding Requiring Action in respect of code element ST116. This element requires companies to ensure service providers meet the same expectations as if the company were
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 15 performing the activities itself. The team felt aspects relating to communications of hazards and risks present at terminals were not well implemented and the management system for third party contractors should be modified to reflect the requirements of this element.
There is an Improvement Opportunity to formalize the assessment process for service providers where company product is held, (for example, but not limited to toll service providers and terminals) (ST118).
2.3 Team Observations Concerning Accountability Code
The team reviewed the elements of this code at the company’s headquarters in Calgary, at its operating site in Sarnia and with employees responsible for third party operations.
The team found that the company generally met or exceeded the requirements set forth in this code section with one exception related to third parties, detailed below.
In Sarnia the team found that the company is relying on its involvement in the Bluewater Community Advisory Panel (BCAP) for meeting a portion of the requirements of this code. Several of the opportunities described below relate to the efficiency and effectiveness of this process. The team believes a strong BCAP is important to the Chemical Valley and encourages the company to work with other members to fully utilize the BCAP to help achieve the requirements in the Accountability Code.
2.3.1 Operating Site Communities
The team felt the Best Practice for External Affairs (BPEA), by drawing together all the various stakeholders under one plan and defining the specific communication activities, goals and responsibilities assigned to each group based on their specific communication needs is a Successful Practice.
With regard to the Best Practice for External Affairs, the team felt an Improvement Opportunity would be to advocate for wording changes to more accurately reflect the purpose of the program, and lessen the appearance of the plan being a public relations exercise.
As mentioned in the introduction to this section the company relies on the BCAP in satisfying some of its commitment to community dialogue. The team feels there is a missed opportunity for the CAER committee to use the BCAP as an additional source of information to find out what the public wants to know about emergencies (how best to keep them informed, when to inform them) and, generally, information about just living next to Chemical Valley.
There is an Improvement Opportunity for the company to provide leadership to develop, in concert with other member companies, a process allowing the CAER committee to better understand and satisfy community communication needs by utilizing the BCAP.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 16 There is an Improvement Opportunity in the management system for community dialogue to review Accountability Code elements AC125-AC127. Please refer to the list of suggestions that follow.
Some aspects to consider are:
develop a more precise geographical definition and targeting of the site’s local residential community in terms of close-in neighbours most likely to be impacted by release scenarios
reassess the borders of the defined local community (now bounded by Wellington St. to the north and Ontario St. to the northeast) to include a more spherical zone of influence
utilize a shell concept (concentric rings) to define the specific content and method of delivery of communication to the neighbouring community
consider putting more emphasis on their near neighbours by developing a similar dialogue process (to the BCAP) with specific members of the close-in community to ensure that more local concerns are addressed
The site issues a community newsletter, “Neighbour News’, which includes a three year emissions reporting component. There is an Improvement Oppo rtunity in the comments section to provide comments relevant to the statistics and years being reported and refrain from simply making statements that cast a positive light on the company and deflect attention away from the statistics being presented.
Although not new to this re-verification, the team felt that the company’s continued use of the Emergency Preparedness Fact Sheet, which was jointly developed by industries operating in the area in 1997, was a good practice because of its excellent format.
Broader exposure of this fact sheet to CIAC members would be beneficial and the team believes an Opportunity for Improvement would be for the company to submit a template of the sheet to the CIAC library for members use.
There is an Improvement Opportunity to include radio station call letters and frequencies in community fact sheets.
2.3.2 Other S takeholders
The team reviewed elements related to Public Policy (AC138-AC140) and Transportation Corridor (AC145). For these sub-sections implementation is aligned with the team’s expectations
There is an Improvement Opportunity to ensure aspects related to TransCAER job scope, process, roles and responsibilities are defined, documented and transferred during the management of people change process.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 17 3. TEAM OBSERVATIONS ON THE COMPANY MANAGEMENT SYSTEM It is a requirement of Responsible Care that companies have a documented, self-healing management system or systems capable of identifying and responding to deficiencies and otherwise supporting continual improvement across all company business units, functions, and sites and as a framework for implementing the Responsible Care Commitments.
The verification team studied IOC’s management system(s) and compared and contrasted the attributes of that system(s) to those of a self-healing overall management system as discussed in the CIAC Management System Guide.
Overall the company has developed, documented and implemented a superb management system integrating CIAC Responsible Care commitments with the company’s Operations Integrity Management System (OIMS).
The OIMS framework consists of eleven elements each of which is expected to have five fully implemented characteristics based on the Plan, Do, Check and Act cycle: Scope & Objectives; Process and Procedures; Responsible & Accountable Resources; Verification and Measurement and Feedback and Improvement Mechanisms. All systems are audited on a routine basis and all have owners responsible for developing annual improvement plans.
An IOC corporate team, the Operations Integrity Steering Committee (OISC) is charged with ensuring all requirements resulting from the commitment to Responsible Care are met and for ensuring separate programs are implemented where OIMS does not have an equivalent. The team actively manages/influences all aspects of the activities put in place to ensure compliance and is actively involved in recommending to the signing executive that the annual attestation to CIAC may proceed.
Although flagged in the previous re-verification report as a best practice it is worth repeating this time around to encourage sharing with CIAC member companies.
The company’s Operations Integrity Management System (OIMS) with its direct management by the company’s Operations Integrity Steering Committee is an example of a Successful Practice. OIMS is a sophisticated and durable managing system which allows for the successful integration and implementation of the Responsible Care Codes of Practice.
The verification team’s related observations to the company management system(s) are as follows:
3.1 Observations on the PLAN step
During the PLAN Step of the management system, the company decides what the goals of the company are and how they will be met. In determining those goals, it is expected the company will look inward, across its operations, but will also look outward, considering the expectations of: stakeholders; regulatory requirements; relevant CIAC Responsible Care Commitments and supporting tools; and other industry benchmarks.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 18 In considering the PLAN Step of IOC’s management system, the verification team observed numerous examples, some of which are presented below.
The company does extensive external and internal benchmarking. One example, which relates to its CIAC commitment, is its review of company injury frequencies with CIAC peer companies as reported by SHARE. The company also utilizes the large internal Exxon/Mobil global injury database to help establish priorities and goals.
Examples of obtaining stakeholder and regulatory input into the planning process were observed in the Public and Government Affairs group’s BPEA process, the Environmental Business Planning Process and as inputs into the Occupational Health Management process.
The team also observed the company’s process to review, analyze and implement the new Responsible Care Codes of Practice.
It is worthwhile to reiterate that each element of the OIMS Framework requires “Feedback and Improvement Mechanisms” and “Scope and Objectives” components which are continuously updated and routinely audited (for implementation and effectiveness).
The team’s opinion is that the company has exceeded expectations in implementation of the ‘Plan’ component of the management system. 3.2 Observations on the DO Step
During the Do Step in the management system, the company converts the decisions of the PLAN Step into action and ensures awareness and understanding by all involved.
In considering the DO Step of IOC’s management system, the verification team observed the excellent team structure present and how it effectively supports the OIMS framework and allows for a full integration of the company’s commitment to Responsible Care (and a clear understanding of where the 151 Code elements fit into the OIMS). Included is the provision of necessary resources, the assurance that standards, work processes, procedures and programs are developed and documented and that initial and on-going training has been conducted and is effective. However, as noted above, there are opportunities to increase awareness of Responsible Care by name with its employees, third parties and other stakeholders.
The team concludes that implementation of the ‘Do’ step generally exceeds expectations. 3.3 Observations on the CHECK Step
During the CHECK Step in the management system, actions carried out in the DO Step are assessed to determine if they are actually being carried out according to plan, and whether they are achieving the desired outcomes and delivering continual improvement.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 19 The company’s audit process is world class as is its ‘Incident Investigation and Analysis’ process. The suite of performance measures is comprehensive, adaptable and reviewed routinely and frequently. In considering the Check step of IOC’s management system the verification team found implementation exceeded expectations.
3.4 Observations on the ACT Step
During the ACT Step in the management system, the company translates the results of the CHECK Step into corrective actions for improvement and this is greatly facilitated by the company’s culture of continuous improvement. This is, in itself, facilitated by the measures associated with the audit process, the attention to detail in the follow up process associated with corrective actions performance review in the stewardship of each OI element and the on-going and continuous review of performance metrics.
The team is of the opinion that implementation of the Act step has exceeded expectations.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 20 4. TEAM OBSERVATIONS ON THE RESPONSIBLE CARE ETHIC AND PRINCIPLES FOR SUSTAI NABILITY Each CIAC member company is formally committed to the ethic of “Doing the right thing, and being seen to do the right thing.” This ethic, along with the principles for sustainability is expected to guide the company’s decision making and practices. In conducting the verification, the team is looking to understand how well the ethic is understood and adopted within the company, and the degree to which the principles inform the manner in which the company does its business.
The verification team carefully observed IOC’s decision making processes and actions and compared and contrasted the attributes of those with the attributes of a company guided by the Responsible Care Ethic and Principles for Sustainability as discussed in the Responsible Care Commitments (Appendix E). The verification team’s related observations on the company’s application of the Responsible Care Ethic and Principles for Sustainability are as follows:
The team believes seven of the eight principles for sustainability were amply demonstrated during the team’s three days of on-site interviews as well as the one day planning and orientation meeting. Although not missing, the company acknowledges its efforts in the promotion of Responsible Care by name will have to improve and several examples were provided that may help in this area.
One example of how the ethic drives the company relates to its active involvement in broadening the reach of the very successful Industrial Education Cooperative (IEC) program developed in Sarnia by valley industry.
The company estimates that greater than 95% of all site contractors are involved with IEC and it is generally acknowledged that the program has helped deliver a low contractor injury rate. This success has prompted the company to attempt to extend the initiative to its Nanticoke refinery area. Although this initiative is led jointly by the chemical and refinery operations, because of the far reaching implications of this program the team wishes to acknowledge the company’s dedication to the concept and their wish to extend its reach.
5. VERIFICATION TEAM CONCLUSION As a result of the examination conducted, and in consideration of the observations communicated within this report, 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 Finding Requiring Action identified during the verification, as summarized in the Executive Summary and discussed in detail in the report. The verification is complete and no further involvement is required by the verification team.
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 21 Chemistry Industry Association of Canada
ATTACHMENT 1: COMPANY RESPONSE TO VERIFICATION TEAM REPORT On behalf of IOC I have reviewed this verification report. The observations and conclusions contained in the report have been discussed with the verification team.
I would like to thank the CIAC Responsible Care Re-verification team for the complete and thoughtful review of our managing systems and implementation of the Responsible Care expectations. The resulting report, in my view, reflects an accurate and objective assessment of our managing systems and our commitment to the Responsible Care ethic and codes of practice.
We are proud of our managing systems and our representation of the Responsible Care ethic, but also realize that there is always room for continuous improvements. I agree with the team’s ‘finding requiring action’, and an action plan to address the finding will be developed and implemented to improve our managing systems.
We are pleased to see that the team was able to identify eight (8) “successful practices” within our organization, and look forward to sharing them with other CIAC members to help them meet and further their Responsible Care commitments.
We value the independent perspectives provided by each member of the team and the identification of opportunities for improvement. They will be reviewed and implemented as appropriate for our organization.
Bob Hutchinson Manager Petrochemicals Imperial Oil Limited July 15, 2011
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ATTACHMENT 2: INTERVIEW LISTS
A: Company Personnel Contacted During Verification Process Name Position Location
Bob Hutchinson Manager Petrochemicals Calgary Don Millett Supplier, Distributor, Customer Mgmt Calgary Tom Hague Basic Chemicals Senior Account Executive Calgary Brian Johnson Rail & Marine Calgary Adrian Michielsen TransCAER Calgary Omar Biceroglu Environment Calgary Reinhart Dumschat Occupational Health Calgary Heart Searle Public Affairs Calgary David Shimada Road Transport Calgary Paul Sabatini Sarnia Chemical Plant Manager Sarnia Tim Spenner Manager Safety, Security, Health & Environment Sarnia Rob Menzies Site Health & Safety Advisor Sarnia Tim Flemming Turn Around Leader Sarnia Shawn Zettel Safety Advisor Sarnia Jim Walker JH&SC Sarnia Muriel Burnley JH&SC Sarnia Peter Cobb Process Manager, Sarnia Chemical Plant Sarnia Peter Kawamura Process Safety Engineer Sarnia Julie Ferguson Community and Aboriginal Affairs Advisor Sarnia Terry Quaid Security Leader and OIMS Coordinator Sarnia Jim Bellrose Fire Marshall Sarnia Peter Noble Manager, Polymers Products Technology Sarnia Karen Carroll Environmental Specialist Sarnia Meline Goulet Environmental Specialist Sarnia Michelle Gerlitz Regulatory Affairs Advisor Calgary Peter Forristal Public Policy & Regulatory Affairs Manager Calgary
Responsible Care Verification Report for Imperial Oil Chemicals, Feb, 2011 Page 23
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