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 [email protected] 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