Document 89VgmD5wRX4nJ0ZdKa4BGrqo

Advocacy and Responsible Care Background and Challenge During 1992, the Public Advisory Panel advised that they perceived some of the industry's lobbying positions and activities were not congruent with the philosophy and principles of Responsible Care. They were particularly concerned about some state level government relations and issues like, ''openness and the protection of confidential data", "toxic use reduction", and "acceptable risk compared to continuous improvement". CtfA staff and member company government relations personnel also expressed concerns that conflicts, real or perceived, between our advocacy positions and elements of Responsible Care could reduce effectiveness of both the initiative and CMA's Advocacy efforts. The Association's management convened an ad hoc staff matrix team to review the role of advocacy with respect to the Responsible Care initiative, and the effect of the Responsible Care Guiding Principles and Codes of Management Practices on the association's advocacy activities. Their challenge was to ascertain whether there were irreconcilable differences, and if not, to outline ways the industry could ensure alignment and congruency of messages and their delivery. The matrix team reviewed its findings with CMA committees, the Responsible Care Coordinating Group and the Board Responsible Care Committee. The BRCC supports the findings and recommendations of the matrix team. Findings and Recommendations Among some critical audiences there was a perception of conflict between CMA's advocacy activities and elements of Responsible Care. When the details were debated, the concerns were usually misunderstandings of CMA's policy position or Responsible Care. Host significant misunderstandings were about: o The voluntary nature of Responsible Care vs mandatory government programs, o The concept of continuous improvement in Responsible Care vs total compliance requirements of regulatory programs, o The role of the Responsible Care Principles in establishing advocacy policy. Because these conflicts represented misunderstandings of the fundamental nature of advocacy and of Responsible Care, the matrix team developed discussion papers to assist staff and members in understanding the relationship between advocacy and Responsible Care. These papers will also serve as models for the development of additional discussion papers. The discussion papers are "evergreen" in nature and should be distributed to staff and members. Comments on the papers will be considered by the ad hoc matrix. Recommendations CMA should take the following actions to insure that the general attributes of Responsible Care and advocacy are understood and that conflicts are avoided: 1) Develop an overall vision statement for CMA that puts Responsible Care and our advocacy efforts into a broader context of the goals and objectives of the industry. 2) Develop information (discussion papers) for the staff, members, government employees, state CICs and interest groups that discuss and resolve the apparent conflicts, such as the voluntary/mandatory issue, between our advocacy efforts and Responsible Care principles. 3) Add to the current series of training sessions on Responsible Care, a session on the essential attributes of both programs and a review of the procedures to prevent real and perceived conflicts. Materials for the training session would be drawn from the discussion papers prepared by this group. 4) Adopt a procedure, to resolve and develop a response to perceived and real conflicts between Responsible Care elements and CMA advocacy policy positions. 5) Revise the "CMA and Advocacy" statement in the next edition of the CMA Directory. 700976.0970 VEX 12 700976.0971 mex CMA Resource Requirements for Responsible Care Background and Challenge Responsible Care, as adopted, consists of six major elements, including: o Guiding Principles of Responsible Care o Codes of Management Practices o Public Advisory Panel o Member Company Self-Evaluations of Management Practices o Executive Leadership Groups o Obligation of Membership in the Association While activities supporting the implementation of Responsible Care are integrated throughout CMA, administration of the initiative is currently coordinated by the Responsible Care Division which operates in the Communications Department. Division staffing includes two exempt and two nonexempt employees. Additionally, the budget assumes support for member company loaned executives working at CMA to help implement the program and a part-time staff assistant supporting their efforts. Outside purchased services includes funds to support the Public Advisory Panel and funds which would be available in support of CMA standing committees as the Codes of Management Practices are implemented in their respective program areas. Ongoing maintenance support and costs for each of the six codes are budgeted within the operating division with continuing implementation responsibility for each Code. Revenue assumes that the supporting material developed for each Code such as publication and video resources will be sold at a level to recover cost and generate some offsetting revenue for the program. Findings and Recommendations The Board Responsible Care Committee recognizes that in order to carry out optimum support, including these recommendations for enhancing the credibility, the Responsible Care function in CMA should be organized as a separate operational Department. As a Department, coordination of all program elements throughout the Association will be facilitated. And, creation of the Responsible Care Department will signal the public that the industry regards its public commitment as equal to all other Association work. CMA's management should organize and staff the Responsible Care Department consistent with work load and resources available to the Association. Staffing of the Responsible Care Department will be achieved primarily through the reallocation of existing CMA staff. The only staff additions 700976.0972 VEX recommended are those the BRCC sees as necessary to carry out essential aspects of administering Responsible Care (e.g., mutual assistance and the Partnership Program). The Responsible Care Department staff will be responsible for overall administration of the initiative. Their responsibilities will include: staffing the Responsible Care Coordinating Group, and its subgroups; staffing the Public Advisory Panel; coordinating and supporting the mutual assistance networks (Executive Leadership Groups, Regional Coordinator Groups, and, along with the State Affairs Department and the State Councils, the Practitioner Networks); operating the Electronic Bulletin Board; coordinating with the Regulatory Affairs Department the development of resources to assist members in implementing the Codes of Management Practices, and measuring progress; working with the Government Relations Department in coordinating Responsible Care internationally; working with the Communications Department on Outreach activities; working with member companies on meeting the obligations of the initiative; and managing the Responsible Care Partnership Program. The Responsible Care Department will continue to be supplemented by staff and resources allocated to other functional areas of CMA. The Department will also receive direct support through the involvement of industry "loaned executives". The BRCC recognizes that due to budget and priority realities, it is unlikely all of the optimum resources will be available to the Association or to the Responsible Care Department in 1993/94. CMA's Standing Committees and staff should identify and implement TQM processes to maximize benefits derived from available funding. This must be a primary responsibility of the Responsible Care Department Head. Total CMA management expenses recommended for the Responsible Care Department are $1,204,400. This is an increase of 28% from the FY 1992/93 projected results. It represents $689,000 in staff and related expenses and $515,400 in outside purchased services. The cumulative projected expense summary for Responsible Care Association-wide is attached. The right hand column titled "unfunded" represents items deleted from consideration in order to meet Finance Committee budget recommendations. 700976.0973 QEX < 7 0 0 9 7 6 .0 9 7 4 YEX CMA RESPONSIBLE PARK DEPARTMENT 5/4/93 CHEMICAL MANUFACTURERS ASSOCIATION RESPONSIBLE CARES CODES CUMULATIVE SUMMARY Projected FY 1992/93 Results Proposed FY 1993/94 Budoat Below-tha-Lina Unfunded FY 1993/94 Requests Rasoons-lble Carea Code-CHA Standing or Special Commit*--i pollution Prwntlon-Envlrofw<fiti>l ant Committee: Siaff and Kalaiad Expanw Standing Committee Requested Outside Purchased Services: TRI Database Pro^pet Environmental AMiant Poeuaant Sull Company Tool Kit Watt* Survpy Source Reduction Workbook Raporilng Package Subtotals: 201,900 290,000 -0-0- 40,000 -0- 35,000 * 566,900 * 176,600 -0- 247,000 -0-0-0- 40,000 -0- R13 N/A 0 463,600 IBB,000 ttl 30,000 1 30,000 11 40,000 24 10,000 29 -0- 0 296,000 Product Stewardship-Health and Safaty Committee: Staff and Ralatad Expansat Standing Committee Requested Outside Purchased Services; Riak Character lga'tlon/Hsnapsment Salas Training Product/Procass Daslgn Manual Public Measures of Programs Haaaurawant of Intamal Parforaanca Product Stewardship Implementation Guide Lifa Cycla Analysis Review Guidelines Subtotals Employs* Haalth A Safety-Health t Safaty Co--ittaa: Staff and Ralatad Expenses Standing Coaanlttoa Requested Outs Ida Purehasad Services; Coda Overview Vldao Generic Exposura Aaaaasaant Incident Investigation Guide Contractor Safaty Guide OSHA Reform-Implementation Support OIIR Coda Measure OIIR Systati Maaauraaant Manager's Guide to laplaaant Coda Inforsiation Sharing System Safaty Standards Coaplianoa Manager's Guide for OHOS Subtotals: t 230,300 -0-0-0-0-020,000 -0-0- t 250,300 0 57,600 35,000 -0-0-0-o -0-0-0-0-0-0- * 92,600 t 226,100 * -0- 30,000 2 60,000 1 20,000 10 30,000 N/A -0-0-0-0- t 366,100 -0-0-0-010,000 7 10,000 4 5,000 20 20,000 26 0 45,000 0 113,100 -o- 15,000 11 15,000 B 25,000 4 10,000 1 10,000 6 35,000 6 -0- -0-0-0- -0-0-0- -0-o- -015,000 3 10,000 12 40,000 13 10,000 19 5,000 *ZS 0 223,100 60,000 CAER-Health and Safaty Co--ittaa Staff and Ralatad Expanses Standing CoMsittaa Requested Outside Purchased Sarvicas: Coda Measurement System Communi ty Essrpaney Response Guide CAER Awards Program Plant Open House Guidelines Small Site Guide State Workshop Guide Subtotals: 0 166,600 -0-0-0-0-0-o- 0 166,600 * 172,100 * -o- 20,000 N/A 26,000 2 -0-0-0-0- 216,100 20,000 2 -0- 10,000 17 10,000 16 20,000 23 40 ,000 26 * 100,000 -64- 700976,0975 CHEMICAL MANUFACTURERS ASSOCIATION RESPONSIBLE CARE* CODES CUMULATIVE SUMMARY Responsible Cara* Code-CMA Standing or Special Coewlttea Projected FY 1*92/93 Results Proposed FY 1993/94 Budget Below*the-Line Unfunded FY 1993/94 Requests Prooti Safety-Engineering and Operations Cowittee Staff and Related Expenses Standing Committee Requested Outside Purchasad Services: * PROSPECT Heasureeent System PIPER Systaa Information Sharing Training Guide-Worker Qualification Proean Safety Resource Guide Manager Guide, Audits Matrix Guide-Regulatory Inspections Accident Database Subtotals: Distribution-Distribution Coswilttaa Staff and Related Expanses Standing Coaaittee Requested Outsida Purchasad Services: Carrier Assassaent Support Responder Training Video Risk Workshop Development Performance Measures Code Iwplseentstion Aids TRANSCAER Support Distribution Risk Management TRANSCAER State Education Enhanced CHEHNET Capabilities Industry Responsa/Coaplianca Training Subtotals: Administrative Functlons-Rasponslble Cara* Coordinating Croup Staff and Related Expanses Special Coaaittee Requested Outside Purchased Services: Public Advisory Panel Responsible Care* Consultants Self-Evaluation Tracking Systaa P\*>lie Opinion Survey Annual Progress Report Code Progress Reports Turnkey Coda Workshops Subtotals TOTALS: * 146,600 -030,000 -020,000 -0-045,000 $ 261,600 172,100 40,000 R3 -0- -0-0-0-0-0- 0 212,100 0 -0- -025,000 *6 30,000 14 10,000 15 30,000 16 15,000 22 -0- t 110,000 * 242,500 -085,000 -0-010,000 30,000 -0-0-066,400 433,900 * 237,900 0 130,000 7,500 1 85,000 2 20,000 8 60,000 9 20,000 N/A 10,000 N/A -0-0-0-0- 0 440,400 -0-0-0-0- -050,006 9 30,000 821 30,000 27 50,000 30 * 290,000 * 480,400 150,000 150,000 50,000 79,000 30,000 -0-0- 939,400 S2.tZll.i399 * 679,000 150,000 fll 216,000 1 50,000 2 79,000 3 30,000 4 -0-0- 01,204,000 S3.il27.i499 0 202,000 -0-0-0-0-0125,000 5 30,000 86 357,000 Sl.iZ99.i999 -84b- ^97 i 70097*