Document 3QXZnyaGMaJ2dkYBRo60N0yrn

TO: Distribution TGG: JCL: ERT: MJH: AJO: RE XF:_________ ______ _ Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 28, 1990 RESPONSIBLE CARE VIST/DISTRIBUTION CODE OF MANAGEMENT PRACTICE You have been sent a copy of Vista's comments to CMA on the subject Code. Further, I wanted to draw your attention to the issue of our internal resources to implement portions of the Code. I only received written comments from two manufacturing locations, however, they are illustrative of the issue. The plants will have difficulty meeting distribution code obligations with existing staff and organization. As indicated by the attached comments, they will be looking to Houston, S&T and Environmental, for implementation help in multiple areas. However, we have the same staff and organizational problems here. Based on this issue and the increasing DOT regulatory activity I am proposing to have a meeting in the near future to review our future needs in these areas and begin planning to meet them. I know S&T has some plans in the organization area and this meeting will help us all understand those as they relate to our future needs. I'll contact you in the near future regarding a meeting date. T. G. Grumbles dlj .14 Attachment Distribution: R. D. Gamblin, G. Draper, P. C. Gowan, T. H. Huffman, J. A. DeBernardi VVV 000013531 FROM:U13^8 OKC TQ:UISTA HOUSTON TO: T.G. Grumbles PUG 13, 1590 3:58PM 274 P. Interoffice Communication FROM: DATE: H. Garrison August 13, 1990 SUBJECT: RESPONSIBLE CARE DISTRIBUTION CODE VIST/ The following comments are offered on the proposed Distribution Code of Management Practices: 1. More than any other code reviewed thus far, this Code seems to be fashioned such that most of the self "evaluation and program development/revision/implementation will be at the corporate level. I am not aware of corporate staffing capable of addressing the demands and needs of this Code. Except for a very few items, the Plant staffing can not take on this expanded scope of responsibility. Specific areas where I feel this is the case: 1.2 Regular evaluations of chemical distribution risks. 1.3 Idencification/implemontation of risk reduction measures . 2.1 Process of monitoring changes in, and interpretations of, regulations and industry standards. 2.3 Ongoing program for providing guidance/information to carriers/contractors. 2.4 Regular review of-----carrier and contractor* compliance. 3.0 Carrier Safety Fitness (in it's entirety). 4.5 Ongoing program for providing guidance and information to customers, distributors and other receivers on proper unloading and storage procedures. 4.6 Process for selecting/regular auditing of fitness of storage and handling facilities. Throughout the draft, the phrases "member company chemicals'*, "member company requirements", and " member company facilities" are found. These should be changed to reflect singular possessive member company's. Otherwise it implies a much broader scope --- one that is far beyond Vista's resources and capability. VVV 000013532 FROM:UISTA OKC TOJUISTfi HOUSTON qUG 13. 1990 3:59PM 274 P.22 RESPONSIBLE CARE --- DISTRIBUTION CODE August 13, 1990 Page 2 3- Item 5.3 makes sense when training emergency response agencies for our particular hazards and situation; however, as written, it seems to imply that our materials and facilities should be made available whenever they want them and for whatever reason. 4. From my perspective 5.4 and 5.5 can be combined. They are redundant with other codes. Specific dialogues on distribution will not occur. They will simply be a part of a general process of dialogue of other code subjects, A better item would be for a channel of dialogue to be established and maintained with .................... 5. Although it does not impact OKC, Item 5.1 may be a problem for Vista. CTIRP addresses ground transportation incidents fairly well but does not address marine, pipeline or air transportation modes very well (if at all). 6. I (HDG) don't think this Code will be very effective without the carrier and contractor organizations having input and/or endorsing CMA's efforts. I don't see this Code impacting or influencing railroads who have monopolistic markets to do anything to change their practices proactively. I just don't feel as good about this Code as I do others because there is too much that is outside the Plant's direct control or influence. If it was broken down according to a corporate responsibility and a local manufacturing responsibility, I might feel better about what will be expected of us and what it's Impact will be. This response was prepared in large part with input from Brent White. H. GARRISON PLANT MANAGER HDG/gsc Code.813 cc: Brent White VVV 000013533 To: T. G. Grumbles Interoffice Communication From: Date: Subject: J. Friend August 13, 1990 Responsible CARE's Distribution Code Tom Randolph and I reviewed the subject Code of Management Practice. We assume the following will apply: 1. S&T will be responsible for elements 1.2, 1.3, 2.3, 3.1, 3.2, 3.3, 4.5, 4.6 and 5.4. 2. Manufacturing will be responsible for elements 4.2, 4.3 and 5.1. 3. Manufacturing and S&T will both be responsible for elements 1.4, 4.1, 4.4 and 5.5. 4. Your group and S&T will both be responsible for elements 1.1, 2.1, 2.2, 2.4, 5.2 and 5.3. Those items that Manufacturing has some responsibility for are all reasonable. However, we will have work to do in order to achieve full implementation. We have no comments on the other elements except that there will be a great deal of work required. mbr cc: TSR KLF VV* 000013534