Document kmYQyzpMknZK22QQe6Xy3XD3D

TO: Distribution rGG: JOB & FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles February 13, 1989 RESPONSIBLE CARE/VISTA ENVIRONMENTAL POLICY STATEMENT VISTA Attached are the handouts and overheads used during the subject meeting. Below are the highlights and action items from the meeting: 1. Vista has an obligation to communicate the content of the CMA Responsible Care Program to employees. We propose to do this by emphasizing that implementation of the Vista Environmental Policy Statement will allow Vista to meet the objectives of Responsible Care. 2. A copy of the Vista Environmental Policy Statement with revisions suggested at the meeting is attached. Most of the discussion at the meeting involved what pinpointed programs or effort would be needed to adhere to the principles listed. It was decided that the next step would be to have a middle management briefing to get consensus on the policy statement, 3. The proposed communication plan was generally approved. We will begin to work on the Management video. 4. Specific action items are as follows: a. Revise Policy Statement and get a review of grammar etc. by PR - TGG b. Begin to work on the video - TGG/MSR c. Define concern with word "fully" preceding comply - TGG d. Arrange for additional Management briefing meeting - ALL T. G. Grumbles dlj .550 Attachment Distribution: J. Burns, J. Ball, J. Weidner, N. Frost, R. Ferrell, G. Draper, R. Gamblin, R. Dale 0000G6812 iza CHEMCAL MANUnCTURBtS 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 of chemical 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. I To promote the principles and practices of Responsible Care by ahflring experiences and offering assistance to others who produce, handle, use, transport or dispose ofchemicals. VVV 000006813 >* RESPONSIBLE CARE A Public Commitment SUMMARY DESCRIPTION Responsible Care Program Elements he Guiding Principles for Responsible 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 compancyowmpilal ny responsibility. It will be assembled pledge to operate according to the principles and moderated by an experienced facilitator 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 Following association adoption of the guiding believe require industry response. The panel principles, various CMA committees will begin will critique (but not approve) all proposed development ofCodes 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 individual Code of Management Practices will Advisory Panels at the local or regional level come 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 action or a substantial public concern to which post of a "CAER Code of Management Practices" the industry shouM 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. management, and plant operations. Based upon Effective performance evaluation is a critical 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 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. VVV 00000681^ t SUMMARY DESCRIPTION (Continued) Two additional objectives are served by Member Company Self-Evaluations of Management Practices. The first is to provide feedback from the membership on the value and relevance of codes of management practices and 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 bers in dealing with government, the public and 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 management practice evaluation program will be developed by a designated work group for the | board of directors' consideration and approval, j The work group will be requested to define the mechanics of a practical system based on mem ber company self-evaluation of their progress. Evaluations will be coordinated through the member companies' executive contacts and will be designed to maximize the value to compa nies' efforts to improve their performance. Due to their varying size and circumstances, j member companies will not be expected to be at the same level of performance for each Code of Management Practices at the same time. However, it will b3 expected that each member company will be able to report continued progress. To facilitate and support each member com pany's continual improvement in responsible management of chemicals. Executive Leadership Groups will be formed to provide an opportunity for executive contacts to periodically discuss progress and share experiences with each other that have been successful. These regional groups of ten to twenty executive con tacts will meet several times a year to review 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 association's officers, executive committee and board of directors. Endorsement of the Responsible Care initiative will be an Obligation ofMembership in the asso ciation. Each member company's executive contact is expected to make a commitment to Responsible Care by: a) signing the Guiding Principles for Responsible Care of Chemicals statement; b) communicating the commitment to Responsible Care to employees; and 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. i A member company's obligation to Responsible Care applies to those segments of the company's operations included in the CMA dues base (CMA Definition of Chemical Sales). Member companies are also expected to par ticipate in the development of the codes and pro grams. The Codes of Management Practices are intended to include mileposts that provide a road map for responding to industry priorities and the public's concerns. Member companies are expected to make good-faith efforts to move up the milepost ladder and meet the expecta tions of the Responsible Care initiative. In an extreme case, where a member com pany has consistently not conducted its opera tions in accordance with the guiding principles and program elements of Responsible Care, association representatives will meet with the member company's executive contact to seek the company's positive involvement in the program. If this fails to produce a commitment to pursue the objectives of Responsible Care, the executive committee and board could take appropriate actions including the disassociation of the com pany from membership after due process requirements have been met. 00Q06S15 VVV 0 VTSTA CHEMICAL COMPANY ENVIRONMENTAL POLICY Vista Chemical Company recognizes that it's activities in producing and transporting chemical products can potentially impact the environment and communities surrounding it's operating facilities. In recognition of this, the company will conduct it's activities in such a way as to effect prudent protection of public health and the environment. Accordingly, Vista is committed to the following principles. 1. .Fully comply with all laws and regulations related to environmental quality and public health protection in all of it's activities. 2. : Maintain an environmental quality assurance program to . ensure that operations are in full compliance with company -^policies, governmental permit limitations, and regulatory requirements. 3. Strive to reduce waste generation in all media by pursuing source control technology and involving all employees in waste minimization efforts. 4. Assess the potential for emergencies involving chemical releases which would impact the environment and surrounding communities, and strive to reduce the potential for and impact of such events. -1- VVV 000006816 5. Inform and educate employees,surrounding communities, customers, carriers, contractors and government agencies of the health and environmental hazards of the chemicals it makes, uses and sells. These activities will involve recognizing and responding to community concerns regarding environmental issues. 6. Determine that each new or existing product can be made, used, handled and disposed of safely with adequate employee, : environmental and public health protection. 7. To participate with the governmentand other parties in ereat lag^ responsible laws, regulations and standards to protect the workplace, community, and environment. Maintain an awareness of and sensitivity to environmental responsibility among all Vista employees through an ongoing program of information and education. 9. Consider safety and health, environmental control and waste minimization as an essential and integral part of new process and facility design and construction. 10. Continuously strive to reduce the risk to employees and neighbors posed by chemical substances used, Li> \ CO tv. transported by Company looeeiano. , produced, and -2- VW 000006817 RESPONSIBLE CARE: A Public Commitment VVV 000006818 General Message To DEMONSTRATE THE CHEMICAL INDUSTRY WILL RESPOND TO PUBLIC CONCERNS BY CONTINUOUSLY IMPROVING PERFORMANCE IN HEALTH, SAFETY, AND ENVIRONMENTAL QUALITY. 0000063*9 General Purpose Improve industry performance in HEALTH, SAFETY AND ENVIRONMENTAL QUALITY. VVV 000006820 Reasons Continued low standing with the public. SARA 313 Emissions Availability. This is a period of REAUTHORIZATION OF MAJOR ENVIRONMENTAL LAWS. Public and customers need REASSURANCE THAT THE INDUSTRY'S PROCESSES AND PRODUCTS ARE CONTROLLED RISKS. VVV 000006821 Key Program Elements Established Guiding Principles Codes of Management Practice Public Advisory Panel Member Company self-evaluation OF PROGRESS Executive leadership groups Responsible care is on obligation of membership in CMA VVV 000006322 Logical Extension of CAER Activities Performance based program: a PR effort not With Citizens Advisory panel improvement can be made in ways THE PUBLIC WILL RECOGNIZE AS PROGRESS, AND BEING RESPONSIVE TO THEIR CONCERNS Communication of progress to LEGISLATORS AND PUBLIC TO ATTAIN QUALITY REGULATIONS Compliment existing Company PROGRAMS MEETING SAME OBJ ECTIVES vvv 00000682 3 Vista Communication Plan Basic Goals 1. Convey concepts, general PRINCIPLES AND SPECIFIC IMPACT OF RESPONSIBLE CARE AND Environmental Policy Statement 2. Demonstrate management COMMITMENT Proposal 1. Develop a video with Vista Executive Management as "STARS" 2. ChemNeus Articles a . Introduction b. Progress Reports 3. Prepare materials for "local" meetings VVV 000006624 Steps Brief TODAY Executive Management 2. Introduce to Plant Managers and other Houston Management 2/16-3/16 3. ChemNews Article - last of March 4. Complete video and field MATERIALS FOR USE - MID-APRIL VVV 000006825 VISTA CHEMICAL COMPANY ENVIRONMENTAL POLICY Vista Chemical Company recognizes that it's activities in producing and transporting chemical products can potentially impact the environment and communities surrounding it's operating facilities. In recognition of this, the company will conduct it's activities in such a way as to comply with all laws and regulations related to environmental quality and public health protection in all of it's activities. Accordingly, Vista is committed to manage our business according to the following principles. 1. 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. 2. Reducing waste generation in all media by pursuing source control technology and to involve employees in waste minimization efforts. 3. Assess the potential for emergencies involving chemical releases which would impact the environment and surrounding communities, and strive to reduce the potential for and impact of such events. VVV 000006826 4. Inform and educate employees, surrounding communities, customers, carriers, contractors and government agencies of ENVP0LIC the health and environmental hazards of the chemicals it makes, uses and sells. These activities will involve recognizing and responding to community concerns regarding environmental issues. 5. Determine how each new or existing product can be made, used, handled and disposed of safely with full attention to employee, environmental and public health protection. 6. Participate with the government and other parties in developing responsible laws, regulations and standards to protect the workplace, community, and environment. 7. Maintain an awareness of and sensitivity to environmental responsibility among Vista employees through an ongoing program of information and education. 8. Consider safety and health, environmental control and waste minimization as an essential and integral part of new process and facility design and construction. 10. Continuously strive to reduce the risk to Vista employees and neighbors posed by chemical substances used, produced, and transported within our communities. VVV 0000068Z7 2/13/89