The Canadian Chemical Producers' Association Codes of Practice: Manufacturing

Purpose

The member companies of the Canadian Chemical Producers' Association (CCPA) are committed, as a condition of membership, to the policy of "Responsible Care". This code governs member company actions in meeting the guiding principles of that policy as they relate to all aspects of the commercial production of chemicals and chemical products by the member company and toll manufacturers.

Practice of this code is intended to result in:

* the protection of people and the environment through the responsible management of all facilities and materials during manufacturing;
* the assurance that the management systems necessary for the responsible operation of the manufacturing site are in place and are functioning effectively;
* the confidence of the community and employees and other people on site that they know the manufacturing hazards and associated risks that could have an impact on them and that they and the environment are protected from these hazards.

Guiding Principles

The guiding principles of this code as they reflect those of the "Statement of Policy on Responsible Care" are:

i) manufacture chemicals and chemical products in a manner which protects people and the environment from hazards;
ii) provide information about the hazards and associated risks of on-site chemicals, chemical products, processes and equipment to employees, other people on site, and toll manufacturers, and to those in the community who have an interest;
iii) make Responsible Care an early and integral part of the planning process leading to new chemicals, chemical products, process, equipment or facilities;
iv) apply this code to existing, modified, and new chemicals, chemical products, processes, equipment and facilities;
v) know the laws and regulations concerning manufacturing, and meet or exceed them in letter and in spirit;
vi) be sensitive and responsive to community concerns about manufacturing operations;
vii) work actively to assist governments in developing public policies, legislation and regulations governing the manufacture of chemicals and chemical products.

Code of Practice

1. General

Each member company shall have written policies, standards and procedures which govern all aspects of the manufacture of chemicals and chemical products. Responsibility shall be clearly defined for generating, implementing, auditing, and updating them, and for taking corrective action. These policies, standards and procedures shall meet or exceed all applicable laws and regulations in letter and in spirit.

Each member company shall have hiring standards and training criteria commensurate with responsible manufacturing requirements, conduct regular performance assessments, take action to maintain employee competence, and ensure with due diligence the equivalent performance from contractors working within the plant environment.

Each member company shall ensure with due diligence that toll manufacturers meet the guiding principles of this code in contracted operations performed for member companies. Toll manufacturers shall be provided with information about hazards and risks associated with contracted operations.

Each member company shall work actively, alone or through selected organizations, and, if possible, in consultation with other affected stakeholders, to assist governments in developing public policies, legislation and regulations governing the manufacture of chemicals and chemical products.

Chemicals and chemical products will not be manufactured unless this can be done in accordance with this code.

2. Employee, Community and Environmental Protection

Each member company shall have management systems in place to protect the safety and health of its employees and other people on site, the community and the environment from any harmful effects of its materials and operations.

The member company shall:

2.1 identify and evaluate on a regular basis potential safety, health and environmental hazards and associated risks, and work to minimize these risks through hazard elimination, engineering controls, procedures, education and the use of personal protective equipment;
2.2 monitor its safety and health performance as well as the working environment with the objective of identifying and minimizing actual or potential occupational safety and health problems;
2.3 prepare an emergency plan which addresses potential emergencies on and around the site which involve the company's materials or processes and assist the appropriate authorities in developing and communicating an emergency response plan for the community (*);
2.4 provide information to employees, other people on site and interested people in the community about the materials handled, processes and equipment, related hazards and associated risks and the procedures for their control, and respond to community and public concerns (*);
2.5 be aware of all effluents and emissions to the environment, monitor those for which it is necessary, and implement plans for their control when necessary. Develop and maintain plans and procedures to minimize the effects of accidental spills or emissions;
2.6 minimize the generation of waste materials through reduction, recycling, recovery and/or reuse. Waste shall be managed in an environmentally sound manner. Where hazardous waste elimination or reduction through treatment or destruction is not practicable, these wastes must be contained in a secure manner and monitored (refer to the hazardous waste management code of practice for further details);
2.7 assess the environmental impact when a facility is closed or demolished and take action to protect people and the environment.
(*) (refer to the code of practice on community awareness and emergency response (CAER) for further details)

3. Design and Construction of Facilities

Each member company shall have written policies, standards and procedures for siting, design, construction and commissioning of new facilities.

The member company shall:

3.1 perform and document a hazard analysis and risk assessment during the design stage of any facility, and act to minimize and control any hazardous situations;
3.2 establish site selection criteria which minimize any adverse impact on the community, the environment, industrial neighbors, utilities, and transportation routes;
3.3 establish and implement criteria for buffer zone requirements for new or existing sites;
3.4 incorporate in the design, measures which will minimize the effects on people and the environment which could remain or develop after closure or demolition of facilities;
3.5 develop, implement and audit safety standards which protect employees, construction personnel, the public and the environment during construction, commissioning and start-up;
3.6 recognize the CCPA's community right-to-know policy by providing information to all interested people at the planning stage of new facilities and by responding to their concerns.

4. Operations

Each member company shall have written operating, engineering and maintenance procedures which specify conditions for the responsible operation of any facility during normal or abnormal circumstances.

The member company shall:

4.1 perform and document a regular hazard analysis and risk assessment of the operating facility and take action to minimize identified risk;
4.2 have written and up-to-date procedures which cover all phases of operation, including start-up and shutdown;
4.3 have written and up-to-date procedures which protect personnel during the maintenance of the facilities;
4.4 take action to prevent injury, damage and harm to people and the environment from explosion, fire or uncontrolled releases;
4.5 have a management system to control and record changes and modifications to equipment, processes, materials and associated computer hardware and software;
4.6 institute security procedures and systems which protect the facilities and address possible security threats;
4.7 maintain systems and procedures to minimize risks to safety, health and the environment during the handling and storage of all materials used and produced;
4.8 audit and update these procedures on a regular basis.