RESPONSIBLE CARE- - \

The Chemical Manufacturers Association

cfig-QV-3
Works to be Part of the Solution

by: William M. Archer

The Chemical Manufacturers Association (CMA) represents over

170 leading companies that account for over 90% of the industrial
chemical production in the U.S. These companies have joined
together to establish the Responsible Care" Program. Through this
initiative all CMA members have committed to continuously improve
in the responsible management of chemicals with respect to
health, safety and environmental considerations. The cornerstone
of the Responsible Care initiative is a set of 10 Guiding
Principles. These are listed in Attachment A.

Part of Responsible Care is the establishment of Codes of

Management Practice on various subjects which incorporate the
Guiding Principles into expected practices. The Codes are
intended to serve as objectives that will complement any existing
programs or practices that member companies have in place to
achieve the same goals. Responsible care is thus intended to be
an integral part of the existing program within each company, and
not a replacement or duplication.
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Several of the Guiding Principles and Management Codes deal

with waste minimization and recycling. The most directly
applicable code is the Waste and Release Reduction Code, which
has been redrafted as the Pollution Prevention Code (see
Attachment B). while this code deals primarily with waste
reduction at member companies facilities, some aspects of the
code will benefit customers. First; as emphasis is switched from
waste treatment to waste minimization, companies will become more
reliable suppliers, less vulnerable to production interruption
from permitting complications. Second, the code promotes the
sharing of technical information and experience with customers
and suppliers, and supports efforts to develop improved waste
) minimization techniques. Some of this information may prove
valuable to customers.
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 Another Management Code being drafted that relates to waste
minimization is the Product Stewardship Code. One of the key
practices being drafted into this code is for companies to
Ifmaintaina process for developing and handling products that
responds to public needs, while minimizing health and safety
risks and adverse environmental impacts". This practice and
others are given in this draft code in Attachment C.

As a member of CMA, Sandoz is part of the Responsible Care

initiative. Sandoz Chemicals Corporation, the dyes and chemicals'
arm of Sandoz, is incorporating the Responsible Care objectives
into its existing programs of waste minimization and product
stewardship. In addition to Responsible Care, Sandoz is finding
that other programs, such as its ongoing Quality Improvement
Process, are good tools in achieving waste minimization
successes.

Waste minimization efforts have been underway at Sandoz

Chemicals for years. In manufacturing, Sandoz has had numerous
successes in reducing wastes and emissions using a variety of
techniques. Upgrading old equipment to new technology reduced
solvent air emissions in one process by roughly 90%. Changing
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solvents in another process eliminated the generation of about
100 tons per year of hazardous waste. In two instances we have
found ways to turn production wastes into usable by-products,
saving disposal costs and generating sales dollars. We invested
hundreds of RtD hours to develop a modified production process
that has reduced the discharge of a SARA compound to wastewater
treatment by 80%.

As the obvious waste minimization opportunities are

realized, Sandoz has moved toward a more formalized program to
identify and implement the less obvious or technically complex
ideas. This has included establishing waste minimization
committees at production facilities and a Corporate Waste
Minimization Steering Committee. Waste Minimization has also
been established as one of three Quality Themes for Sandoz
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 Chemicals Corp. in 1991. Being a Quality Theme means that every
employee in the company will participate in a team that
3 brainstorms opportunities related to Waste minimization.

Sandoz has also been active in product stewardship for

years. Like many other companies, Sandoz is focusing research
efforts on developing products and processes that minimize health
and safety risks and adverse environmental impacts. At our
Research and Development Center in Charlotte, research is being
conducted to find safe, effective substitutes for SARA listed
components in some products.

As the leading U.S. producer of sulfur dyes, Sandoz is

actively researching ways to reduce the sulfide content of sulfur
dyes and eliminate the use of sulfide additives during dyeing.
This research has resulted in the recent introduction of a low-
sulfide black sulfur dye, the first of a new generation of
reduced-sulfide sulfur dyes that offer both safety and
environmental benefits over conventional sulfur dyes.

New technologies are also being researched that will offer

considerable environmental advantages. In a joint venture with a
hi-cmpans-fSandoz is developing biological products
that will reduce or replace harsher chemicals. The first such
product is a specially cultured fungus that is being used in the
pulp/paper industry. This fungus, applied to wood chips before
stockpiling at the mill, substantially degrades the pitch in the
wood prior to other processing. This allows mills to avoid many
of the problems associated with pitch and reduce chemical usage
in the pulping process.

Responsible Care is being very well received by other

industries and the public. Its common sense approach to sound
management of chemicals and the sharing of information will
likely make it a model for other programs across the country.

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 Attachment A

Guiding Principles for

RIESPONSIBE
CARE
A Public Commitment
As a member of the Chemical Manufacturers
Association, this company is committed to
support a continuing effort to improve the
industrys 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 opemtions.

W To develop and produce chemicals that can be manufactured,

transported,used and disposed ofdely.

W To make health, safety and environmental considerations a pri-

ority in our planning for all existing and new products and
.P
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W To report promptly to officials, employees, customers and the

public, information on chemical-related health or environmental
hazards and to recommend protective measures

W To counsel customers on the safe use, transportation and disposal

of chemical products.

W 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 supportingresearchon the

health, safety and environmental effects of our products, processes
and waste materials.

W To work with others to resolve problems created by past handling

and disposal ofhazardous substances.

W To participate with government and others in creating responsible

laws, regulations and standards to safeguard the community,
workplace and envkonment.

To promote the principles and practices of Responsible Care by

CMA
CnQAcU
sharingexperiences and offering assistancetoothers who produce,
LMNvF*cTIRws handle, use,transport or dispose of chemicals.
*ssocuMN

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 Attachment B

POLLUTION PRolENTION CODE OF MANAGEMENT PRACTICES

NOTE: Normal Text indicates the language approved 4/90 for the Waste and
Release Reduction Code (WARR); t e x t shawn i n i t a l i c s and bold i s
the d r a f t language t h a t adds t h e uaste management c o n c e p t s to t h e UAUR
Code.

Purpose.
This Code is designed to achieve ongoing reductions in the amount of all
contaminants and pollutants released to the air, water, and land from
member company facilities. These reductions are intended to respond to
public concerns with the existence of such releases, and to further
increase the margin of safety for public health and the environment.
The Code is also designed to achieve ongoing reductions in the amount o f
wastes generated at facilities. These reductions are intended to help
relieve the burden on industry and society o f managing such wastes in
future years.
In implementing the Code, each company should strive for annual
reductions, recognizing that production rates, new operations, and other
factors may result in increases. Despite these fluctuations, however,
the goal is to establish a long-term, substantial downward trend in the
amount of wastes generated and contaminants and pollutants released.
Quantitative reduction goals will be established for giving priority to
those pollutants, contaminants and wastes of highest health and
environmental concern.
T h i s code a l s o i n c l u d e s p r a c t i c e s t h a t address t h e broader w a s t e
management issues beyond s o u r c e r e d u c t i o n and w a s t e and release r e d u c t i o n
e f f o r t s . Each member company must manage remaining w a s t e s and releases
i n a manner t h a t p r o t e c t s t h e environment and t h e h e a l t h and s a f e t y o f
employees and t h e p u b l i c .

This Code complements, and should be implemented in conjunction with

current and future Codes of Management Practices. Key terms are defined
in the Glossary, which should be consulted for assistance in interpreting
the provisions of this Code.

Relationship to Guidinq Principles.

Implementation o f this Code helps achieve the following Guiding
Principles:
o To recognize and respond to corrmunity concerns about
chemicals and our operations;
o T o d e v e l o p and produce chemicals t h a t can be
manufactured, t r a n s p o r t e d , used and d i s p o s e d of s a f e l y .
Pollution Prevention Code
(The expanded Waste 81 Release Reduction Code)
Member Review Draft---January 7, 1991 --- Page 2

o To make health, safety, and environmental considerations a

priority in our planning for all existing and new products
and processes;
o To report promptly to officials, employees, customers
and the public, inforuation on chemical-related health or
environmental hazards and to recommend protective
measures.

o To operate our plants and facilities in a manner that

protects the environment and the health and safety o f our
employees and the public;
o To extend knowledge by conducting or supporting research on
the health, safety, and environmental effects of our
products, processes, and waste materials.
o To promote the principles and practices of Responsible Care
by sharing experiences and offering assistance to others
who produce, handle, use, transport, or dispose of
chemicals.
o To uork with others to resolve problems created by past
handJing and dispsal of hazardous substances.

o To participate uitb govemment and otbers in creating

responsible l w s , regulations and standards to safeguard
the community, workplace and environment.

o To promote the principles and practices of Responsible

Care by sharing experiences and offering assistance to
others who prodvce, baodle, use, transport or dispose of
chemicals.

Managanent Practices (WARR).

Each member company shall have a waste and release reduction program
which shall include:
1. A clear commitment by senior management through policy,
communications, and resources, to ongoing reductions at
each of the company's facilities, in releases to the air,
water, and land and in the generation of wastes.
2. A quantitative inventory at each facility o f wastes
generated and releases to the air, water, and land,
measured or estimated at the point o f generation or release.
3. Evaluation, sufficient to assist in establishing reduction
priorities, o f the potential impact of releases on the
environment and the health and safety of employees and the
pub1 ic. ,'1
* Pollution Prevention Code
(The expanded Waste ii Release Reduction Code)
DRAFT
Member Review Draft---January 7, 1991 --- Page 3

4. Education of, and dialogue with, employees and members of

the public about the inventory, impact evaluation, and
risks to the community.
5. Establishment of priorities, goals and plans for waste and
release reduction, taking into account both community
concerns and the potential health, safety, and
environmental impacts as determined under Practices 3 and 4.
6. Ongoing reduction o f wastes and releases, giving preference
first to source reduction, second to recycleheuse, and
third to treatment. These techniques may be used
separately or in combination with one another.
7. Measurement o f progress at each facility in reducing the
generation of wastes and in reducing releases to the air,
water, and land, by updating the quantitative inventory at
least annually.
8. Ongoing dialogue with employees and members of the public
regarding waste and release information, progress in
achieving reductions, and future plans. This dialogue
should be at a personal, face-to-face level, where
possible, and should emphasize listening to others and
discussing their concerns and ideas.
9. Inclusion of waste and release prevention objectives in
research and in design o f new or modified facilities,
processes, and products.
10 # An ongoing program for promotion and support of waste and
release reduction by others, which may, for example,
include :
a. Sharing of technical information and experience with
e u s t m r s and suppliers;
b. Support of efforts to develop improved waste and
release reduction techniques;
C. Assisting in establishment o f regional air monitoring
networks ;
d. Participation in efforts to develop consensus
approaches to the evaluation of environmental, health,
and safety impacts o f releases;
e. Providing educational workshops and training materials;
f. Assisting local governments and others in
establishment of waste reduction programs benefitting
the general public.
Pollution Prevention Code
(The expanded Waste & Release Reduction Code)
Member Review Draft---January 7, 1991 --- Page 4

Pericrdically evaluate uaste management practices associated

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with operations and equipment at each facility, taking into 1
account community concerns and health, safety, and
environmental impacts and implement ongoing improvements.

12. Conduct initial and periodic revieus of contractors* and

toll manufacturers' relevant facilities and operations used
by the member company and verify that sound waste
management practices are used to protect the environment
and the health and safety of employees and t h e public.

13. Implement engineering and operating controls at each member

company facility to improve prevention of , early detektion
of, and response to releases to gruundwater.

14 - Assess prior operating and disposal practices at each

active or inactive facility awned by a member company and
implement an ongoing program to resolve identified
problems, taking into account community concerns and
health, safety, and environmental iupacts.

Industry Trend Data.

To develop and maintain statistical industry trends,CMA will collect
currently available data. Each company shall report annually to CMA, or
its designated agent, for each facility:
o Releases of substances as reported under SARA Section 313;
and
o Wastes generated, a s defined and reported in CMA's annual
waste survey.

Member $e 1 f -Eva 1 uat i on.

Each member company shall report annually to CMA, or its designated
agent, the stage of implementation of each management practice i n this
Code. The reports shall be on the member self-evaluation form attached
as Attachment A.
* . Pollution Prevention Code
(The expanded Waste & Release Reduction Code)
Member Review Draft---January 7, 1991 --- Page 5 DRAFT
-> Glossary o f Terms

As used in this Code, key terms are defined as set forth below. Note
that these definitions may be broader than regulatory definitions, and
that adherence to this Code does not relieve a company of the obligation
to meet Federal, state and local regulatory requirements.
Facility - A site used for chemical manufacturing, processing,
refining, packaging, R&D, distribution or related commercial activity.
Recycle -
A practice which regenerates or processes a material from a
process to recover a useable product or material for reuse.
Release -
Any emission, effluent, spill, discharge or disposal to the
air, land, or water, of any pollutant or contaminant, whether routine or
accidental, at or from a facility. The term does not include shipment or
distribution of chemical product, nor release to the environment as part
of normal and intended use of a product by the consumer.
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Reuse - A practice that reemploys a material from a process either as
an ingredient in a process to make a product, or as an effective
substitute for a commercial product in a particular function or
application.
Source Rechtction - A practice that reduces the amount of any release
or waste generated at the source, including closed loop recycle and reuse
before exit from a process. The term includes, among other practices,
equipment and technology modifications, process and procedures
modifications, reformulation and redesign of products, substitution o f
raw materials, and improvements in housekeeping, maintenance, training
and inventory control.
Treatment - A practice, other than recycle or reuse, that alters the
physical, chemical, or biological characteristics or the volume of a
uaste t h o u g h a process or activity separate from the production of a
comnercial product or the provision of a service.
Waste - Any gas,
liquid, or solid residual material at a facility,
whether hazardous or non hazardous, that is not used further in the
production of a comercial product or provision of a service and which
itself is not a commercial product.
 Attachment C

Product Stewardship Code (Draft 7 / 3 1 / 9 0 ) , Pago 1

P r o d u c t Stewardship Code of hlanagement Practices

PURPOSE AND SCOPE

The goal of t h e Product Stewardship Code i s t o h a w a management
Fhilosophy and commitment t o d e s i g n , develop, manufacture and s e l l
products t h a t a r e s a f e and environmentally sound when handled, used and
disposed of a s d i r e c t e d .

Companies a l s o w i l l have. t h z r e s p o n s i b i l i t y t o develop a c c u r a t e and

s u f f i c i e n t information about t h e h e a l t h , s a f e t y and envlronmental
e f f e c t of t h e i r products and t o ensure t h a t t h i s information is
a v a i l a b l e and communicated t o those who handle, u s e and d i s p o s s of
member company products. F i n a l l y , companies w i l l have t h e
r e s p o n s i b i l i t y t o enable those t h a t handle, u s e and d i s p o s e of member
company products t o do so s a f e l y -- w i t h an emphasis on customer
e d u c a t i o n and evaluation.

RELATIONSHIP TO RESPONSIBLE CARE AND GUIDING PRINCIPLFS

The code helps achieve s e v e r a l of t h e Responsible Care Guiding
Principles:

c) to mako h e a l t h , s a f e t y and environmental c o n s i d e r a t i o n s a p r i o r i t y

in p l a n n i n g f o r a l l e x i s t i n g and new products a s w e l l a s p r o c e s s e s ;
o t c develop and produce chemicals t h a t can t e manufactured,
t r a n s p o r t e d , used and disposed of s a f e l y ;

o t o extend knowledge by conducting o r supplying r e s e a r c h on t h e

h e a I t E , s a f e t y and environmental effects of member campmy
p r o d u c t s , processes and wasto m a t e r i a l s ;

o to counsel customers on the s a f e ust3, t r a n s p o r t a t i o n and d i s p o s a l

of chemical products;

o t o report promptly t 2 o f f i c i a l s , employees, customers, aFd t h e

p u b l i c information on chemical-related h e a l t h o r envircnmerita!
hazards and to recommend p r o t e c t i v e measures;

o t o promote t h e p r i n c i p l e s and p r a c t i c e s of Responsible Care by

s h a r i n g experiences and o f f e r i n g a s s i s t a n c e t o others who produce,
handle, use, t r a n s p o r t o r d i s p o s e ,of
. chemicals.

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 Product Stewardship Code (Draft 7/31/90), Page 2

MANAGEMENT PRACTICES
Hember companies shall have an ongoing product stewardship process
that includes the following management prnct ices:

1. maintain a commitment through policy, management leadership,

communication and resources to ongoing improvements in the product
stewardship process --beginning with senior management and
extending throughout the organization;

2. maintain a process for developing and handling products that

responds to public needs, while minimizing health and safety r i s k s
and adverse environmental impacts;

3. maintain a knowledge base to assess potential adverse effects of

products and product uses;

4. identify reasonably foreseeable uses and misuses of products

as well as evaluate risk levels during new product development;
periodically update the evaluation for existing products;
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5. develop and implement actions appropriate to risk levels
t o minimize risks;

6. select contract manufacturers who meet company health, safety, and

environmental standards for the specific product or appropriate
operation as well as periodically audit their performance;

7. furnish customers, distributors, and contract manufacturers with

information and guidance to enable the proper handling, use, and
disposal of products ;

8. develop and implement r i s k management controls--

appropriate t 9
%e ~ i s klevel --
to enable the proper handling, use, end disposal
of products ;
9. evaluate and do business with customers, distributors, and
resellers who meet applicable safety, health, and environmental
criteria based on the products sold; provide assistance as
appropriate ;

10. protect product quality --

including performance as it impacts
health, safety, and the environment;

11. educate and, as needed, update sales, marketing, and technical

staffs -- emphasizing the reasonably foreseeable uses and misuses
of products -- so they, in turn, ciSn counsel customers and
distributors in the responsible use and disposal of products;
require these staffs to provide feedback to their management;
Product Scewardship Code (Draft 7/31/90), Page 3
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12. develop and continuowly improve programs t h a t lead to source
reductions, recovery, recycling and, where appropriate, disposal
of products throughout thp_ir lifecycle;

13. educate, train and, as needed, update employees (i.e. , R&D,

distribution) on the health, safety, and environmental aspects of
products.

MEMBER SELF -EVALUATION

RELATIONSHIP TO OTHER CODES OF MANAGEMENT PRACTICES

This code complements, and should be implemented in conjunction
with, current and future Codes of Management PrActices.