Document O3Y0BqQRbQD9QDZR1ayO2RBL1

TO: Distribution TGGf jet: M1$3: XF: ------ FROM: DATE: Interoffice OTTRT. Communkation iU1JJ T. G. Grumbles March 1, 1989 VISTA ENVIRONMENTAL PROGRAM REVIEW POLICY STATEMENT/CMA RESPONSIBLE VISTACARE Attached is an agenda for the subject meeting to be held Wednesday, March 8, 1:00-2:30 in Conference Room 3B. The purpose of the meeting is to introduce the CMA Responsible Care Program, review the draft Vista Environmental Policy Statement and present our communication plan for both. I realize not all of you can attend. The 8th was the best we could do to have the most people available this month. Those who can't be there will be given the opportunity individually to give comments on the attached. Since the formation of Vista, we have not had a pinpointed company policy statement regarding the corporate environmental philosophy or policy. A draft of the policy statement is attached. Also, CMA has implemented a new program called Responsible Care. This program requires CMA members to commit to efforts that will result in continuous improvement in 10 program areas. The Responsible Care Principles and a summary description are attached. We believe that by implementing the Vista Environmental Policy Statement principles we will meet the required obligations of Responsible Care. Vista has an obligation to communicate the Responsible Care Program in the near future. It would be best to do this in conjunction with the publication of the Vista policy. This would allow us to communicate implementation of Vista principles and programs versus implementation of a CMA program. Implementation of the Policy elements will require Management and resource commitment from all functional areas of the company. \ (JV T. G. Grumbles dlj .568 Attachment Distribution: J. Inbody, R. Gerlach, J. Stoner, J. McCulley, J. DeBernardi, T. Huffman, G. Draper, D. Kuhn, B. Larsen, W. B. J. Vogel, D. Andersen, R. Flammer, V. Weiss, W. L. McClain, N. Frost cc: J. Ball, R. D. Gamblin, J. Burns, J. Weidner, R. Ferrell vw 00G0G6893 AGENDA WEDNESDAY, MARCH 8, 1989 1:00-2:30 CONFERENCE ROOM 3B Purpose: 1) Introduce the CMA Responsible Care Program elements and proposed communication plan. )2 Introduce Vista's Draft Environmental Policy Statement 1. Introduction & Purpose 2. Review of Responsible Care a) Elements b) Vista obligations c) Proposed Communication Plan 3. Present Vista Environmental Policy Statement a) Elements b) Specific impact of each element 4. Discussion 5. Review Action Items RDG 5 Min. TGG 15 Min. TGG 20 Min. All 15 Min. TGG 5 Min. .568 OOOOOb^9^ vw Vista Environmental Policy February 28,1989 DRAFT VISTA CHEMICAL COMPANY ENVIRONMENTAL POLICY Vista Chemical Company produces and transports chemical products that can potentially impact the environment in communities surrounding our operating facilities. The Company complies with all laws and regulations related to environmental quality and public health protection in all of our activities. Vista recognizes the responsibility we have to our employees, the surrounding communities, customers, carriers, contractors and government agencies to conduct our business activities according to the following environmental principles: Vista will inform and educate employees, surrounding communities, customers, carriers, contractors and government agencies of the health and environmental hazards of the chemicals we make, use and sell. These activities will involve recognizing and responding to community concerns regarding environmental issues. Vista will continue to strive to reduce the risk to employees and neighboring publics posed by chemical substances used, produced and transported within our communities. Vista will continue to strive to reduce the potential for emergencies involving chemical releases that would impact the environment and surrounding communities. Vista will foster and maintain an awareness of and sensitivity to environmental responsibility among our employees through an ongoing internal communication program. Vista will maintain an environmental quality assurance program to ensure that operations are in full compliance with Company policies and procedures, governmental permit limitations and regulatory requirements. Vista will determine how each new or existing product can be made, used, handled and disposed of with full attention to employee safety, and environmental and public health protection. * Vista will consider safety and health, environmental control and waste minimization as essential and integral parts of process and facility design and construction. * Vista will reduce waste generation in all media by pursuing source-control technology, involving employees in waste minimization efforts. * Vista will participate with the government and other parties in developing responsible laws, regulations and standards to protect employees, surrounding communities and the environment. February 28,1989 WV 000006895 A CHEMCAL MANUFACTURERS ASSOCIATION Guiding Principles for RESPONSIBLE CARE A Public Commitment As a member of the Chemical Manufacturers Association, this company is committed to support a continuing effort to improve the industry's responsible management of chemicals. We pledge to manage our business according to these principles: To recognize and respond to community concerns about chemicals and our operations. To develop and produce chemicals that can be manufactured, transported, used and disposed ofsafely. To make health, safety and environmental considerations a pri ority in our planning for all existing and new products and processes. To report promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures. To counsel customers on the safe use, transportation and disposal ofchemical products. To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials. To work with others to resolve problems created by past handling and disposal ofhazardous substances. To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. To promote the principles and practices of Responsible Care by aha-ring experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. VVV Ooooo6a<6 t* RESPONSIBLE CARE A Public Commitment SUMMARY DESCRIPTION Responsible Care Program Elements he Guiding Principles forResponsible Another important element in the Responsible TCare ofChemicals is a statement of Care initiative is a Public Advisory Panel, which commitment by each member company will be composed of a cross-section of environ to fully support a continuous effort to mental, health and safety thought leaders. The improve the industry's responsible managpea nel will be an industry (CMA) effort, not a ment of chemicals. Each member compancyomwpilal ny responsibility. It will be assembled pledge to operate according to the principles and moderated by an experienced facilitator i statement and will sign to that effect. This working at the association's direction and will ! signed statement will be considered an obliga serve to assist the industry in identifying and tion of membership in CMA. These guiding developing programs and actions that are principles are based on CMA's 1983 policy state responsive to public concerns and viewed as ment on health, safety and the environment and proactive by key policy groups. Meeting several on the Canadian Responsible Care principles. times a year, the panel will review issues on They also incorporate guidance received from which CMA requires comment and advice as member company executive contacts. well as to discuss subjects that panel members j Following association adoption of the guiding believe require industry response. The panel i principles, various CMA committees will begin will critique (but not approve) all proposed development of Codes ofManagement Practices. Codes of Management Practices and is expected Each set of management practices will focus on to provide early definition of public concerns a different concern.Impetus for developing an involving the chemical industry. Community ndividual Code of Management Practices will Advisory Panels at the local or regional level jome from either an industry belief that there can serve companies and the industry in a simi exists a substantive need to take voluntary lar manner. They will be called for as a mile- j action or a substantial public concern to which post of a "CAER Code of Management Practices" ! the industry should be responsive, or both. and CMA will offer support to facilitate compa Initially, code packages will be considered for nies' formation and operation of these local CAER, transportation, release reduction and panels. i management, and plant operations. Based upon Effective performance evaluation is a critical j [ the implicit obligations of the guiding princi element of Responsible Care. Member | ples, the Codes of Management Practices will be Company SelfEvaluations ofManagement \ designed by identifying expected management Practices, as well as compilation of quantitative practices as objectives rather than prescribing results, will be necessary to meet three vital any absolute or quantitative standard. Since the objectives. In order to build a collective record of codes are intended to serve as objectives, they tangible improvement in the responsible man ! will complement any existing member company agement of chemicals, specific management programs or practices that achieve the same practice codes may call for CMA to collect and j goals. Responsible Care will therefore become maintain statistical trends from data that mem an integral part of the existing company pro bers currently make available to governmental gram, not a replacement or another duplicative organizations. Details of quantitative trend sta overlay. Each Code of Management Practices tistics programs will be defined by task forces ! will be approved by the board after the opportu developing the respective management practice nity for comment by all member companies. code package. GOO t* SUMMARY DESCRIPTION (Continued) Two additional objectives are served by Endorsement of the Responsible Care initiative | Member Company Self-Evaluations of will be an Obligation ofMembership in the asso- Management Practices. The first is to provide ciation. Each member company's executive | I feedback from the membership on the value and contact is expected to make a commitment to relevance of codes of management practices and Responsible Care by: on any additional CMA support activities that may be needed. Second, such evaluations, along with quantitative trend data, will build CMA credibility and confidence on behalf of its mem a) signing the Guiding Principles for Responsible Care of Chemicals statement; b) communicating the commitment to i j bers in dealing with government, the public and Responsible Care to employees; and j other external groups. Each management practice code will contain definition of management practice "progress mileposts" that member companies will use to measure and evaluate their performance ver sus the commitment. Details of the member c) instructing management to make good-faith efforts to implement the Codes of Management Practices, participate in the self-evaluation process, and meet the expectations of the Responsible Care Program. | j ; i management practice evaluation program will A member company's obligation to be developed by a designated work group for the Responsible Care applies to those segments of board of directors' consideration and approval. The work group will be requested to define the the company's operations included in the CMA jdues base (CMA Definition of Chemical Sales), ! mechanics of a practical system based on mem Member companies are also expected to par- ! ber company self-evaluation of their progress. ticipate in the development of the codes and pro Evaluations will be coordinated through the grams. The Codes of Management Practices are i member companies' executive contacts and will intended to include mileposts that provide a be designed to maximize the value to compa road map for responding to industry priorities nies' efforts to improve their performance. and the public's concerns. Member companies Due to their varying size and circumstances, are expected to make good-faith efforts to move member companies will not be expected to be at up the milepost ladder and meet the expecta- ; the same level of performance for each Code of tions of the Responsible Care initiative. [ Management Practices at the same time. In an extreme case, where a member com- ' However, it will be expected that each member pany has consistently not conducted its opera- ; company will be able to report continued tions in accordance with the guiding principles progress. and program elements of Responsible Care, ; To facilitate and support each member com association representatives will meet with the I pany's continual improvement in responsible member company's executive contact to seek the : I management of chemicals, Executive company's positive involvement in the program. : Leadership Groups will be formed to provide an If this fails to produce a commitment to pursue opportunity for executive contacts to periodically the objectives of Responsible Care, the executive j discuss progress and share experiences with committee and board could take appropriate | each other that have been successful. These actions including the disassociation of the com i regional groups of ten to twenty executive con pany from membership after due process tacts will meet several times a year to review requirements have been met. Codes of Management Practices under develop ment, discuss members' progress on existing codes, identify areas where individual compa nies need assistance from CMA or other compa nies, and to address other priority industry issues. Understandings developed during these meetings will be reviewed and acted on by the I association's officers, executive committee and board of directors. [ o0000<>89 VW B