Document N0GdQ4Q14q3Ow1057BDxvVmR

TO*. Distribution Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles September 23, 1991 RESPONSIBLE CARE DISTRIBUTION CODE OF MANAGEMENT PRACTICE 1^ SELF-EVALUATION Attached for your information and review is our scorecard for the subject Code. As you will see, this scorecard is significantly different from others to date. As previously discussed in the selfevaluation guidance and request, this is a result of multiple locations beyond the plant sites being considered as reporting locations. These include functional groups in S&T and for some elements, individual ex-plant shipping and handling locations. Also attached are the following: 1. Explanation of the reporting locations for each element (Attachment 1). 2. Specific changes made in scorecards submitted to Houston. Some changes were made based on discussions with the plants and clarification of applicability. It is important to note any specific changes made at your location as this was our first, and therefore "baseline" self-assessment (Attachment 2). T. G. Grumbles dlj Attachment VVV 000007823 C.ofce,qc lep 9|^ 5 Responsible Care: A Public Commitment CHEMICAL MANUFACTURERS ASSOCIATION MEMBER SELF-EVALUATION FORM DISTRIBUTION CODE OF MANAGEMENT PRACTICES Member Company Name: Vista Chemical Company ResDonsible Care Coordinator Name: Thomas G. Grumbles Address: P.0. Box 19029 Houston, TX 77224 T* - Teleohone (713) 538-3445 vvv 00000782** MEMBER SELF-EVALUATION FORM Risk Management Practices 1.1 Regular evaluations of chemical distribution risks which consider the hazards of the material, the likelihood of accidents/incidents and the potential for human and environmental exposure from release of the material over the route of transport. 1.2 Implementation of chemical distribution risk reduction measures that are appropriate to the risk level. 1.3 Internal reporting and investigation of chemical distribution accidents/incidents, and implementation of preventive measures. Compliance Review and Training 2.1 A process for monitoring changes and interpretations of new and existing regulations and industry standards for their applicability to the company's chemical distribution activities, and for implementing those regulations and standards. 2.2 Training for all affected company employees in the proper Implementation of applicable regulations and company requirements. 2.3 A program for providing guidance and information to carriers, distributors and contractors who perform distribution activities for the company on the company's training and compliance requirements for the activities. 2.4 || Regular reviews of company employee, carrier, distributor and contractor compliance with applicable regulations and company requirements. 1 - 8.33% 1.01% ii 111 IV 100% - V 100% 100% 50% - 50% 50% 16.67% _ 8.33% 16.67% 37.06% 5.08% 23.86% 32.99% 38.5% 5.00% 26.50% 30.00% VI lOttON^TMASEMAB VVV 000007825 MEMBER SELF-EVALUATION FORM Carrier Safety 1 11 3.1 A process for qualifying carriers of all modes and types (common, contract, private and customer controlled) that transport chemicals to and from company facilities that emphasizes carrier safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance. 3.2 Feedback to carriers on their safety performance and suggestions for improvement. Handling and Storage .75% 55.22% .74% 98.51% 4.1 Documented procedures for the selection and use of containers that are appropriate for the chemical being shipped, in compliance with testing and certification requirements, and free of leaks and visible defects. 4.2 Documented procedures for loading chemicals at company facilities that will reduce emissions to the environment, protect personnel and provide securement of the lading during transit. 4.3 Documented procedures for unloading chemicals at company facilities that will reduce emissions to the environment, protect personnel, and provide for safe unloading into proper storage facilities. 4.4 Defined criteria for the cleaning and return of tank cars, tank trucks, marine vessels, and returnable/refiflable bulk and semi-bulk containers, and for the proper disposal of cleaning residues. 4.5 A program for providing guidance and information to customers, distributors, and other receivers on proper procedures for unloading and storing the company's chemicals. 6.25% \ 9.09% 37.50% 50% "50% 75.% 72.73% 111 IV V VI 34.33% 9.70% .74% 25% 6.25% 25% 20% 30% 10% 10% 20% 10% 12.5% 12.5% 18.18% 000007S26 1002QN/CMASEF.TA& MEMBER SELF-EVALUATION FORM 4.6 A process for selecting distributors and other facilities that store or handle the company's chemicals in transit that emphasizes safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance. 4.7 Feedback to distributors and operators of other facilities that store or handle chemicals in transit on their safety performance and suggestions for improvement. Emergency Preparedness 5.1 A process for responding to chemical distribution accidents/incidents involving the company's chemicals. 5.2 1 Documented procedures for making information about the company's chemicals in distribution available to response agencies. 5.3 A program for making facilities and/or training materials available to emergency response agencies. 5.4 Dialogue with state and local emergency planning organizations on the distribution and hazards of the company's chemicals to Improve community preparedness to respond to chemical distribution emergencies. 5.5 Dialogue with the public on their concerns about chemical distribution safety, actions taken by the industry and the company to improve the safety of chemical distribution, and the effectiveness of emergency preparedness and emergency response assistance. 1 II 66.67% III IV V 33.33% - 66.67% 33.33% 9.09% 61.54% 90.91% 38.46% 30% 30% 10% 10% 20% 10% 50% \ 50% 40% 20% ' 20% 10% VI 10Q2GN/CMASEF.TAB V*V 000007S21 ATTACHMENT 1 Reporting "Facilities" for Distribution Code Self-Evaluation Risk Management Practices Element 1,1 - 1 This was considered to be a corporate function. considered. One location was Element 1.2 - 1 This was considered to be a corporate function. considered. One location was Element 1.3 - 1 This was considered to be a corporate function. considered. One location was COMPLIANCE REVIEW AND TRAINING Element 2.1 - 2 Reporting locations considered were: Corporate Environmental Supply & Transportation Element 2.2 - 12 Reporting locations considered were: Core Vista Locations Headquarters Transports Element 2.3 - 202 Core Vista Locations Transports Barge Operations Rail, Freight and Carriers Element 2.4 - 199 International Operations Rail Operations Motor Carrier Group Motor Carrier Group Explant Operations Locations Reporting locations considered Core Vista Locations Transports Barge Operations Rail, Freight and Carriers Rail Operations Explant Operations Locations Motor Carrier Group International Operations VVV OOOOOT828 CARRIER SAFETY Element 3.1 -134 Reporting locations considered: Core Vista Locations Barge Operations International Operations Motor Carrier Group Rail Fright and Carriers Element 3.2 - 134 Reporting locations considered: Core Vista Locations Barge Operations International Operations Handling and Storage Element 4.1 - 16 Motor Carrier Group Rail Fright and Carriers Reporting locations considered: Core Vista Locations International Operations (Houston) Transports (Houston) Motor Carrier Group (Houston) Barge Operations (Houston) Rail Operations (Houston) ExPOG (Houston) In this element the score is based on the functional groups having procedures, versus all locations managed by those groups as in 3.1 and 3.2. Element 4,2 - 10 Reporting locations considered: Core Vista Locations *^v9 Element 4.3 - 10 % Reporting locations considered: Core Vista Locations Element 4.4 - 16 Reporting locations considered: Core Vista Locations International Operations (Houston) Transports (Houston) Motor Carrier Group (Houston) Barge Operations (Houston) Rail Operations (Houston) ExPOG (Houston) 000007529 vvv Element 4.5 - 11 Reporting locations considered: Core Vista Locations Element 4.6 - 3 Reporting locations considered: Rail Operations Transports Element 4,7 - 3 Reporting locations considered: Rail Operations Transports EMERGENCY PREPAREDNESS Element 5.1 - 11 Reporting locations considered: Core Vista Locations S&T (Houston) Element 5.2 - 13 Reporting locations considered: Core Vista Locations Rail Operations Element 5.3 - 10 Reporting locations considered: Core Vista Locations Element 5.4 - 10 Reporting locations considered: Core Vista Locations Element 5.5 - 10 Reporting locations considered: Core Vista Locations ExPOG ExPOG ExPOG ExPOG Transports VVV 000007830 For the self-evaluation Core Vista locations, include all plants and R&D. The following number of locations were considered "active" for the non-plant locations: ExPOG - 52 locations Motor Carrier Group - 58 carriers Rail Operations - 9 locations (shops, etc.) Vista Transports - 2 terminals Barge Operations - 4 carriers International Operations - 47 locations/corapanies/carriers Rail Freight and Contracts - 15 rail carriers It is recognized these numbers will change but it is the percentage of locations at an implementation stage that is reported. Our goal is to increase percentages of total locations at a specific stage. A detailed scorecard specifying the numbers used to obtain the percentages in the scorecard follows this page. VVV OQOOQ7S31 j MEMBER SELF-EVALUATION FORM 1 Risk Management Practices 1.1 Regular evaluations of chemical distribution risks which consider the hazards of the material, the likelihood of accidents/incidents and the potential for human and environmental exposure from release of the material over the route of transport. 1.2 implementation of chemical distribution risk reduction measures that are appropriate to the risk level. 1.3 Internal reporting and Investigation of chemical distribution accidents/incidents, and implementation of preventive measures. Compfiance Review and Training 2.1 A process for monitoring changes and interpretations of new and existing regulations and industry standards for their applicability to the company's chemical distribution activities, and for implementing those regulations and standards. 2.2 Training for all affected company employees in the proper implementation of applicable regulations and company requirements. 2.3 A program for providing guidance and information to carriers, distributors and contractors who perform distribution activities for the company on the company's training and compliance requirements lor the activities. 2.4 Regular reviews of company employee, carrier, distributor and contractor compliance with applicable regulations and company requirements. 1 1 BLN PREM BLN 11 100% 100% 100% III IV - V VI 50% 50% LCVCM ABO LCCP PREM LCLAB OKC ABD LCCP LCLAB LCVCM-- OKC TRANSP-2 BARGE - 4 RF&C-15 INTOPS - 47 AUSTIN ABO OKC BALT BLN LCCP LCLAB LCVCM PREM TRANSP- 2 BARGE - 4 RF&C-15 INTOPS - 47 AUST HAMM BALT TRANSP HDQ HAMM AUST RAILOPS * 9 BALT , MCG - 45 EXPOG-52 MCG-13 HAMM RAILOPS - 9 EXPOPS-8 MCG-45 EXPOPS - 45 TRANSP- 2 MCG-13 000007832 vvv MEMBER SELF-EVALUATION FORM Carrier Safety 3.1 A process for qualifying carriers of all modes and types (common, contract, private and customer controlled) that transport chemicals to and from company facilities that emphasizes carrier safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance. 3.2 Feedback to carriers on their safety performance and suggestions for improvement. Handfing and Storage 4.1 Documented procedures for the selection and use of containers that are appropriate for the chemical being shipped, in compliance with testing and certification requirements, and free of leaks and visible defects. 4,2 Documented procedures tor loading chemicals at company facilities that will reduce emissions to the environment, protect personnel and provide securement of the lading during transit. 4.3 Documented procedures for unloading chemicals at company facilities that will reduce emissions to the environment, protect personnel, and provide for safe unloading into proper storage facilities. 4.4 Defined criteria for the cleaning and return of tank cars, tank trucks, marine vessels, and retumable/reflllable bulk and semi-bulk containers, and for the proper disposal of cleaning residues. I BLN BLN HAMM II III ICVCM ABD AUST LCCP PREM LCLAB OKC HAMM BARGE-4 RF&C -15 INTOPS - 47 PREM LCLAB OKC HAM AUST ABD LCCP LCVCM BARGE -4 RF&C-15 INTOPS - 47 MCG - 58 ABD LCCP BLN LCLAB BARGE INTOPS ABD LCCP BLN WB" AUST ABD LCCP BLN LCLAB AUST AUST LCVCM ABD LCCP PREM BLN LCLAB OKC MCG EXPOG BARGE INTOPS PREM OKC TRANSP RAILOPS HAMM BALT RAILOPS IV V BALT MCG-45 MCG -13 VI BALT BALT OKC BALT BALT LCVCM AUST EXPOG MCG LCVCM PREM HAMM LCVCM OKC PREM HAMM TRANSP vvv 000007833 MEMBER SELF-EVALUATION FORM 4.5 A program for providing guidance and information to customers, distributors, and other receivers on proper procedures for unloading and storing the company's chemicals. 1 HAMM 4.6 A process for selecting distributors and other facilities that store or handle the company's chemicals in transit that emphasizes safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance. 4.7 Feedback to distributors and operators of other facilities that store or handle chemicals in transit on their safety performance and suggestions for improvement. Emergency Preparedness 5.1 A process for responding to chemical distribution accidents/incidents involving the company's chemicals. 5.2 Documented procedures for making information about the company's chemicals in distribution available to response agencies. 5.3 A program for making facilities and/or training materials available to emergency response agencies. 5.4 Dialogue with state and local emergency planning organizations on the distribution and hazards of the company's chemicals to improve community preparedness to respond to chemical distribution emergencies. 5.5 Dialogue with the public on their concerns about chemical distribution safety, actions taken by the industry and 1 the company to improve the safety of chemical distribution, and the effectiveness of emergency preparedness and emergency response | assistance. LCCP PREM BLN HAMM ABD LCCP PREM BLN HAMM II ABD BALT BLN LCCP LCLAB LCVCM OKC PREM RAILOPS TRANSP III RAILOPS TRANSP IV V VI AUST EXPOG EXPOG EXPOG AUST ABO LCCP LCLAB T5^ore EXOPG TRANS LCVCM LCLAB HAMM LCVCM LCCP PREM LCLAB AUST LCVCM LCLAB OKC AUST HOUSTON (S&T) - AUST ABD BALT BLN LCCP LCLAB LCVCM HAMM OKC PREM LCVCM PREM BLN BALT HAMM AUST ABD ABD BALT OKC BALT BLN OKC BALT vvv 00000783 4 _________ ATTACHMENT 2 Specific Changes in Scorecards Submitted In several instances there was some confusion over applicability of code elements to specific locations, or the written guidance given was bad. There may still be some debate over applicability but the following changes were made in individual score cards: Aus tin Austin did not provide a score on multiple elements. The following scores were added. Element Stage 2.4 3.1 4.2 4.3 4.4 5.2 5.2 5.4 5.5 2 2 2 2 2 2 2 2 2 Baltimore Element Stage 2.4 4.5 2 2 Blane Element 2.4 4.5 2 2 Aberdeen Element Stage 2.4 4.5 3.2 2 2 2 yW 0000Q7 S3b LCCP El ement Stage 2.3 2.4 3.1 3.2 4.4 4.5 LCLAB 2 2 2 2 2 2 - Stage 2.4 4.5 2 2 LCVCM Element 2.4 3.2 4.5 2 2 2 Hammond Element Stage 4.4 5 Okc Element Stage 2.4 4.4 4.5 2 2 T* ^- Premiere Element Stage 4.5 2 Elements 2.4 and 4.5 were applicable to plants in most cases because plants do contract carrier, etc., business that is managed by S&T. Please note these changes on the scorecards you submitted as they will serve as our baseline assessment. WV 00000783b