Canadian Chemical Producers' Association
Responsible Care庐 Re-verification 2005-08
of
BASF Canada Inc. (鈥淏ASF Canada鈥?)
(October 2 - 4, 2007)
DISCLAIMER
This document has been produced by a team convened by the Canadian Chemical Producers' Association
(CCPA) to provide guidance to the above company, as a member or partner of the association, in meeting its
obligations under Responsible Care. The material in it reflects the team's best judgement in light of the
information available to it at the time of preparation. It is the responsibility of the CCPA member or partner
company which is the subject of this report to interpret and act on the findings and recommendations in this
guidance document as it sees fit. Any use which a third party makes of this document, or any reliance on the
document or decisions made based upon it, are the responsibility of such third parties. Although CCPA
members and partners are expected to share the results of this guidance document with interested parties, the
association, its member and partner companies, their employees, consultants and other participants involved in
preparing the document accept no responsibility whatsoever for damages, if any, suffered by a third party as a
result of decisions made or actions based on this report.
庐 Responsible Care is a registered trademark of the Canadian Chemical Producers' Association
Re-verification report for BASF Canada 鈥? October 2007 Page 1 of 32
Responsible Care Re-verification: BASF Canada.
EXECUTIVE SUMMARY AND TEAM CONCLUSIONS
A Responsible Care re-verification for BASF was carried out on September 20, 2007 in
Cornwall, Ontario by one member of the Canadian Chemical Producers鈥? Association (CCPA)
appointed team, on October 2 & 3, 2007 in Toronto and Mississauga the three-member
CCPA appointed team and on October 4, 2007 in Windsor by two members of the CCPA
Team, augmented by a local community representative in the communities visited.
In addition to the manufacturing and distribution sites a retail site in Mississauga, associated
with the company's Automotive Refinishing Technologies (ART) section, was also visited. As
well, a phone interview was conducted with employees located at the company's Blackie AB
site. The re-verification included interviews with a cross section of managerial, office,
maintenance and production employees and reviews of documents relating to the various
topics being addressed.
The Canadian Chemical Producers鈥? Association鈥檚 鈥淩esponsible Care Re-Verification 2005-
2008 A Protocol to Help Us Improve鈥? document was used for this re-verification.
The decision-making and actions of BASF are clearly underpinned by the Responsible Care
ethic. The company鈥檚 overall management system is self-healing, seeking to continuously
improve, to identify deficiencies and will likely act to correct them in a timely manner.
The re-verification team is satisfied with the approach used by the company to apply and
meet the requirements of the Responsible Care ethic and management system. The re-
verification process of BASF is now complete with the publication of this report.
Summary of Findings, Opportunities for Improvement, Best Practices and
Extra Miles
This section of the report lists all Findings Requiring Action (FRA), Opportunities For
Improvement (OFI), Best Practices (BP) and Extra Miles found in the body of the text. In all,
the team recorded 8 findings, 21 opportunities and discovered 4 best practices during our
visits.
Progress on action to resolve the Findings Requiring Action will require follow-up at each
Leadership Group Meeting, with the local community dialogue process, in the company鈥檚
annual CEO re-commitment to CCPA, and in the next Responsible Care re-verification (where
the next re-verification team will expect to see decisions pertaining to resolution of the
Opportunities For Improvement). The wording of each Finding Requiring Action, Opportunity
and other comments found in this Executive Summary is identical to the wording used in the
body of the report to avoid any possible misunderstanding of the team鈥檚 intent.
Re-verification report for BASF Canada 鈥? October 2007 Page 2 of 32
Findings Requiring Action
1). It is a finding requiring action that the Crop Protection Division operations are
not included in the corporate Environment, Health and Safety (EH&S) audit process.
2). It is a finding requiring action to do quantitative risk assessment, including
worst case scenarios, for the Automotive Refinishing Technology (ART) facilities in
order to define the geographic scope of impact and, if necessary, to expand the
communication program to accommodate this geographic scope.
3). It is a finding requiring action that the company does not have a process to
assess and evaluate suppliers of chemical goods from a Responsible Care
perspective.
4). It is a finding requiring action that not all items from the security vulnerability
assessments (SVA) have been completed.
5). It is a finding requiring action at Windsor that a documented schedule for
emergency response plan testing is not in use.
6). It is a finding requiring action that BASF Canada does not have 鈥渇low-down鈥?
emission and waste reduction targets.
7). It is a finding requiring action that the Cornwall site safety work order process is
not responsive to employees submitting safety suggestions and work orders.
8). It is a finding requiring action at some second party warehouses and tollers that
a community dialogue and risk communication program is not in place. Either the
second party or BASF can implement the program.
Opportunities For Improvement
1). An opportunity for improvement exists to examine, on an on-going basis, that the intent
of all code of practice elements are being met by the recorded response in the Responsible
Care management database.
2). There is an opportunity for improvement for the Responsible Care Steering Committee
(RCSC) to broaden its mandate to include the review and analysis of the suite of
Responsible Care related performance measures in order to focus on those which best
satisfy the ethic of Responsible Care.
3). There is an opportunity for improvement to modify the current management of change
(MOC) process to include appropriate review when a process hazard analysis (PHA)
trigger criteria has been met.
Re-verification report for BASF Canada 鈥? October 2007 Page 3 of 32
4). There is an opportunity for improvement for the company to follow through on its stated
intention at the Windsor site to resurrect the CAER group in the area.
5). There is an opportunity for improvement in Windsor to provide guidance on criteria for
use, coverage, responsibilities, authorities, limits etc. for the dislocation policy. This is a
useful exercise for community related emergency response as well as transportation
emergency response.
6). There is an opportunity for improvement for the company to follow through on its stated
intention to conduct an energy audit at Blackie in late 2007.
7). There is an opportunity for improvement for the Responsible Care Steering Committee
(RCSC) to develop an oversight role in the development and monitoring of environmental
emission and waste reduction targets.
8). There is an opportunity for improvement to move forward from 1993 as the base
reporting year in all trend charts.
9). There is an opportunity for improvement to examine the use of heat recapture
technology and/or air composting to reduce heat loss from air emission treatment at sites
where this is economically and technically practical.
10). There is an opportunity for improvement for the executive contact to sign the posted
Responsible Care ethic statement.
11). There is an opportunity for improvement to update the Ecology and Safety Policy to
include the Responsible Care ethic statement instead of the old Guiding Principles.
12). There is an opportunity for improvement to add a reference to Responsible Care in
employee brochures where this is not done already
13). There is an opportunity for improvement to post the Responsible Care Commitment
statement at the Toronto facility
14). There is an opportunity for improvement at Windsor to post an up-to-date signed
EH&S policy, Responsible Care Commitment statement, and Responsible Care Ethic
statement.
15). There is an opportunity for improvement at Windsor to include Responsible Care as a
regular agenda item for Joint Health and Safety Committee (JH&SC) meetings and
minutes.
16). There is an opportunity for improvement at the Cornwall site to implement a policy to
ensure proper drum vents are utilized through out the site.
17). There is an opportunity for improvement at Cornwall to improve the management
system that ensures Material Safety Data Sheet (MSDS) copies are current.
18). There is an opportunity for improvement to develop a separate value added statement
related to social responsibility for Canadian operations
Re-verification report for BASF Canada 鈥? October 2007 Page 4 of 32
19). There is an opportunity for improvement for the company to follow through on its
stated intention at the Windsor site to add to its outreach activities by involvement in the
local neighbourhood watch program.
20). There is an opportunity for improvement to implement a process to check that people
do know what to do in an emergency as part of the process to periodically visit with site
neighbours.
21). There is an opportunity for improvement to have regular contact with commercial and
industrial neighbours on risk and what to do in an emergency (and in particular to ensure
TransportAction has been communicated with).
Best Practices/Extra Miles
1). The Responsible Care Scorecard, because of its immediate impact in understanding
the current overall (and local) Canadian Responsible Care status is a best practice.
2). BASF's leadership in bringing ag-product container recycling to the marketplace is a
best practice.
3). Hourly employee involvement in selecting and leading safety meetings are an industry
best practice.
4). The company's Risk Based Distribution Management program is a best practice
The team recommends that CCPA officially recognize this re-verification with an award at the
next suitable occasion.
Signed: Gerry Whitcombe Date: March 30, 2008
Team Leader
For more information on this or a previous re-verification or on the company鈥檚 original report
for verification of Responsible Care-in-Place, please contact your local company site or the
company鈥檚 overall Responsible Care coordinator:
RC Coordinator: David Peters
phone: 289-360-6072
e-mail: david.peters@basf.com
Re-verification report for BASF Canada 鈥? October 2007 Page 5 of 32
1) INTRODUCTION AND OVERVIEW
1a) The Company
This is the report by the verification team on those operations of BASF Canada which are
covered by the company鈥檚 commitment to the Responsible Care initiative of the Canadian
Chemical Producers' Association. A description of the company in Canada and which
operations are covered by this report can be found in Appendix 1.
1b) Responsible Care
Responsible Care is an initiative of the Canadian Chemical Producers' Association
(CCPA) by which the association鈥檚 members and partners commit to be, and to be seen
as, responsible companies within Canadian society. It is based on an ethical approach to
the safe and environmentally sound management of chemicals 鈥? an approach which
started in Canada but has since spread to over 45 countries around the world.
The Responsible Care Ethic:
We are committed to do the right thing and be seen to do the right thing.
We are guided towards environmental, societal, and economic sustainability by the
following principles:
鈥? We are stewards of our products and services during their life cycles in order to
protect people and the environment.
鈥? We are accountable to the public, who have the right to understand the risks and
benefits of what we do and to have their input heard.
鈥? We respect all people.
鈥? We work together to improve continuously.
鈥? We work for effective laws and standards, and will meet or exceed them in letter
and spirit.
鈥? We inspire others to commit themselves to the principles of Responsible Care.
The ethic is supported in Canada by six codes of practice covering relations with the
communities where members鈥? facilities are located and also responsible management
throughout the product life cycle. Information on these codes of practice and related
activities is available from company personnel listed in Appendix 2 of this report, or via
the CCPA web site www.ccpa.ca (click on the 鈥淲ho we are鈥? tab for Responsible Care).
Re-verification report for BASF Canada 鈥? October 2007 Page 6 of 32
1c) Expectations of CCPA members and partners
Each CCPA member or partner company must formally commit to the ethic, principles
and codes of practice of Responsible Care as a condition of membership in the
association.
Progress in implementing these obligations must then be reported to CCPA, both to
peers at special networking meetings and also via a formal reporting system to the
association. Three years is the typical time allowed to new members for implementation.
The association monitors progress and follows up by arranging for assistance where
necessary to ensure that each company eventually meets its commitment.
When a company considers that its management processes are sufficiently
comprehensive that they meet each of the 151 individual code requirements, it advises
the association that implementation is complete to the stage of 鈥淩esponsible Care-in-
Place鈥?. Completion in this sense does not imply that nothing further needs to be done, but
that a key milestone has been reached in a process of continuous improvement.
1d) Verification
A company鈥檚 declaration that the expectations of Responsible Care are being met is an
important first step in the verification process, which leads to confirmation and recognition
of this by a team of industry and public representatives. Verification is conducted to strict
protocols, developed by the association鈥檚 members and others including several critics of
the chemical industry and its operations. The first verification takes place when the
company first states that its performance meets the expected level (Responsible Care-in-
Place). This verification is designed to confirm, for the company鈥檚 peers in CCPA and the
public, the existence of a company wide ethic and management systems which ensure
that the principles and codes of practice of Responsible Care are not only in place but are
also practised and continuously improved within the organization.
Subsequent verifications are also conducted using a different protocol, approximately
every three years after formal acceptance of the first verification, to ensure that the ethic
and management systems of Responsible Care are firmly rooted in all the company鈥檚
operations. This is known as ongoing re-verification.
Each verification is conducted by a team consisting of:
鈥? knowledgeable industry experts with experience in Responsible Care;
鈥? a representative of the public at large (usually with a public interest background
and with experience in Responsible Care gained from serving on the CCPA鈥檚
national advisory panel) and
鈥? one or more representatives of the local communities where the company鈥檚
facilities are located.
Re-verification report for BASF Canada 鈥? October 2007 Page 7 of 32
1d) i) Verification of Responsible Care-in-Place
For the purposes of this examination, a portion of the 151 code requirements is sampled
in depth. These items are grouped into seventeen management systems, each of which
is examined using a series of questions. Some of the questions are sent to the company
in advance of the verification visit, so that supporting documentation, etc. can be
available for prompt examination if desired. Additional questions are asked at the
discretion of the team during the visit.
The approach is 鈥渢op-down鈥? rather than the 鈥渂ottom-up鈥? used in conventional audits, and
the style of questions is intentionally open-ended, so that the answer cannot be a simple
yes/no but calls for explanation. The questioning process starts with the executive
responsible for chemical operations in Canada, and works down through the organization
to examine the senior level intent and the corresponding support by action at the
operating level.
Questions are generally of the following nature:
鈥? does the organization have an effective management system in place to ensure
understanding of Responsible Care?
鈥? what is the process to determine and communicate the acceptable level of
performance?
鈥? what is the process for assessing the performance of the system and effecting
follow-up to meet or exceed the acceptable level of performance?
鈥? what is the process for ensuring up-to-date documentation?
鈥? do sufficient resources appear to be, or are thought by employees to be, in place?
The findings are summarized in a report which highlights:
鈥? actions required by the team before they consider the company meets the
expectations of Responsible Care;
鈥? opportunities for improvement, which are recommended but not mandatory;
鈥? recognition of any exemplary practices of the company which could be a model for
other CCPA members.
The report is given to the company and CCPA, and the company is expected to share the
report with interested persons in its communities as part of its dialogue process. If the
team considers that actions are required before sign-off, they will arrange for follow-up to
confirm that these are complete, and advise the company and CCPA in writing when
these have been met to their satisfaction.
Responsible Care-in-Place verification of BASF Canada
Company Name at the time: BASF Canada Inc. (鈥淏ASF Canada鈥?)
Date of 鈥淚n-Place鈥? verification (visit): May 29-31, 1995
Locations visited: Toronto, Brantford
Team follow-up needed: No
Date of final sign-off: July 1995
This Responsible Care-in-Place verification report is available from the contact at the
company from whom you accessed this report, or from the company contact shown on
page 5 of this re-verification report.
Re-verification report for BASF Canada 鈥? October 2007 Page 8 of 32
1d) ii) Re-verification
Approximately every three years after team acceptance of Responsible Care-in-Place,
the CCPA schedules further verifications using a modified approach. The team is similar
to that for the original verification, with at least one team member from the previous
verification but a different leader.
This is the third re-verification of BASF, the first being conducted in 1999.
Previous Responsible Care re-verification of BASF Canada:
Date of re-verification visit: May 10-14, 2004
Locations visited: Toronto, Cornwall, Windsor
Locations contacted by phone: Abbotsford, B.C., Blackie, AB., Georgetown, ON.
Team follow up needed: No
Date of final sign-off: August 30, 2004.
In re-verification the team probes more deeply to examine how well the ethical basis of
Responsible Care is understood and adopted within the company, and also how effective
are the company鈥檚 management systems in applying the ethical principles throughout the
company鈥檚 operations. This involves not only whether the company intends to do the right
things, but also how it monitors activities and results and takes corrective action when
deviations occur (often referred to as the Plan-Do-Check-Act parts of the management
system).
For re-verification the company is given a more comprehensive list of documentation the
team will need to see. Part of this must be sent to the team so they can study it in
advance. The questioning process is also more open, in that the team does not have to
cover every topic in depth but can probe where they feel it is most relevant for that
individual company, plus any areas where the company itself would like feedback on its
performance.
After studying the information the team meets with the company to plan the visit stage of
the verification, at which a schedule is agreed covering people the team wishes to
interview in depth during the subsequent visit stage of the verification process. Most of
these will be company personnel, but some will be representatives of organizations with
which the company has business relationships 鈥? customers, transporters, etc. 鈥? and of
local communities where plants, etc. are located.
The team examines to determine how strongly the Responsible Care ethic appears to be
part of the company鈥檚 way of doing business, including awareness of Responsible Care
and its implications among the company鈥檚 employees. The examination then progresses
into a broad-ranging review of the company鈥檚 management systems for Responsible
Care, with a special investigation into certain topics highlighted by CCPA in the
verification protocol.
Re-verification report for BASF Canada 鈥? October 2007 Page 9 of 32
The team looks at how effectively the company鈥檚 management systems ensure that
Responsible Care principles and code obligations continue to be met, as established in
the initial Responsible Care-in-place verification. In subsequent verifications, however,
the questioning process also considers how the company tracks and improves its
performance regarding these obligations, including how performance measures are
established and targets met (what is measured, what are the goals and how are they
achieved). Actions taken on concerns, suggestions and recommendations raised in the
last verification report are examined, as are significant issues and incidents that have
arisen since the previous verification. The team then looks at how the company shared
the results of this verification with the local community, and examines how robust the
ongoing process of community dialogue appears to be and how issues and concerns are
being identified and addressed.
The highlighted topics of special focus are ones where the feedback from the verification
process and from the association's members has suggested the value of a closer
examination of the general membership performance and comparison with the intent of
the codes of practice. This does not necessarily imply that any given company is not
performing well, but reveals the range of performance and identifies both cases where
some improvement is recommended and also examples from which others can learn.
The highlighted topics include community dialogue, process safety management, site
emergency preparedness and response, security regarding malicious threats that could
impact public safety or well-being, health effects of products and plant emissions, product
stewardship and 鈥淭ransCAER鈥? outreach. Also examined are emissions of greenhouse
gases, and how companies with emissions of volatile organic compounds are meeting the
intent of a CCPA agreement on this topic with the federal and provincial governments and
environmental groups. Although CCPA has no defined performance expectations for
broader social responsibility, the team also looks at how the company sees and fulfills its
role in this area. The team may also comment on other specific topics where the
company has requested feedback.
The report below presents the findings of the team from this re-verification of BASF
Canada. The report does not address all aspects of Responsible Care, as this was
covered by the report of the original Responsible Care-in-Place verification. Instead, it
focuses more on the items where the team felt there was an opportunity or need for
improvement, plus any improvements or practices which are so significant that they
should be shared with other CCPA members and partners as possible examples.
For more context or explanation of any of the items below, please get in touch with the
contact at the company from whom you accessed this report.
In the following sections of this report, findings requiring action are shown in bold
face. Opportunities for improvement (recommended but not considered mandatory) are
shown in italics, while 鈥渆xtra miles鈥? and best practices are shown underlined).
Re-verification report for BASF Canada 鈥? October 2007 Page 10 of 32
2. General Findings of the Team
2a) Statement on the Ethic
Throughout the interview process the team checked for evidence that the Responsible Care
ethic was visible and at work in the company, guiding the company鈥檚 judgment, decisions and
actions.
Team Findings
The team found that the ethic is well understood and does indeed guide actions and decisions
of most people. There have been many improvements noted since the last re-verification and
a very strong Canadian management positioning of the ethic has been put in place. Robin
Rotenberg, the President of BASF Canada and the Executive Contact to the CCPA has
established an environment where Canadian managers are increasingly exercising
appropriate autonomy within an integrated, matrix style corporate structure. The overall effort
and in particular, that of the Responsible Care Steering Committee, to develop sustainable
Canadian Responsible Care solutions was very evident.
2b) Employee Awareness
Team Findings:
Please refer to section 3e) on page 19.
2c) Overall Responsible Care Management System
It is a requirement of Responsible Care that companies have documented, sound
management systems capable of ensuring that all operations of the company across all
business units, functions and sites meet the ethic, codes of practice and other expectations of
Responsible Care on an ongoing basis. A sound management system drives continuous
improvement, and has the following attributes:
Plan Do
review code requirements document
benchmark best practices train people
get input from stakeholders assign resources
decide on best approach carry out activities
set targets for performance
assign responsibility
Re-verification report for BASF Canada 鈥? October 2007 Page 11 of 32
Check Act
audit follow-up on audit findings
measure performance of system communicate performance, get feedback
measure performance from system reward or correct employees
obtain stakeholders鈥? feedback repeat Plan steps
assess employees鈥? performance
There must be such management systems both for the overall management of the company
and for each code element. This section covers the team鈥檚 findings with respect to this
overall management system, and section 3 below covers the specific code elements that
were reviewed in the re-verification.
Team Findings
There is a comprehensive and competent Responsible Care Management System (RCMS) in
place at the company. It results from the implementation of global company initiatives and
strong Canadian management with some excellent follow up to the last re-verification. Since
that time, the parent company has implemented (in North America) the American Chemistry
Council鈥檚 (ACC) Responsible Care Management System (ACC-RCMS) and they have
recognized and strongly supported the Canadian Responsible Care initiative. During this
same period, BASF Canada has put in place a strong management structure including top
level teams to ensure all branches of the organization are complying and a supporting team to
manage daily (and annual) Responsible Care necessities.
The ACC-RCMS has brought systems standardization to all parts of the company and
recognition of the requirement to comply with Canadian Responsible Care has established a
clear direction for Canadian Management. The current upper level organization structure
consists of a President and reporting to her, the Canadian Executive Committee (CEC), the
Canadian Business Team (CBT) and the Direct Reports Team (DRT).
Reporting directly to the CEC (and to the President upon request) the Responsible Care
Steering Committee (RCSC) consists of the Responsible Care Overall Coordinator and all
Code Coordinators. Their mandate is to ensure all 151 code elements are fully integrated into
the BASF Canada culture and to annually provide recommendations to the President about
attesting to the status of Responsible Care in the company to the CCPA.
A RCSC report is a routine agenda item at the CEC meetings and they also report quarterly to
the CBT. In this way, all important Responsible Care issues and successes get disseminated
throughout the organization and, importantly, the resources necessary for success are
discussed and committed where necessary.
The RCSC has implemented a Responsible Care management database that houses all
information related to the implementation and upkeep of all 151 code elements across all
facilities in Canada.
Re-verification report for BASF Canada 鈥? October 2007 Page 12 of 32
Each Code coordinator is responsible to ensure that the status of all items (within their area)
are updated at least once per year and this along with relevant audit data and findings and
opportunities data from the last re-verification constitute the information utilized in annually
analyzing the status of Responsible Care within the company. This analysis is then used to
recommend to the President to sign (or not sign) the attestation required by the CCPA. The
team did discover, however, that although the corporate EH&S audit process contributed
heavily to an understanding of the overall level of compliance the Crop Protection Division
was not a part of the process.
1). It is a finding requiring action that the Crop Protection Division operations
are not included in the corporate Environment, Health and Safety (EH&S)
audit process.
1). An opportunity for improvement exists to examine, on an on-going basis, that the
intent of all code of practice elements are being met by the recorded response in
the Responsible Care management database.
The system used by the RCSC has been simply documented by the use of an operational
flow chart which, amongst other things, clearly specifies the requirement for annual review
leading to attestation.
The RCSC has developed a Responsible Care Scorecard which measures the performance
of all facilities opposite a suite of Responsible Care areas-of-interest and displays the results
using a colour coded index. This has the effect of immediately and clearly identifying areas
needing work.
2d) Follow-up on Findings in Last Verification Report.
The team reviewed how the company addressed the findings requiring action and
opportunities for improvement cited by the previous verification team in their report to the
company. Certain follow-up items are covered in the specific topics below.
Team Findings
The company has developed an excellent process to deal with findings and opportunities
cited in the previous re-verification report. The items are generalized, added to the
Responsible Care management database and assigned to all facilities who qualify. In this
way each affected facility gets an individual action item which is then tracked to completion
utilizing the reporting features in the database. The RCSC reviews all outstanding action
items and reports to the CEC on progress. In addition, the RCSC has developed a
Responsible Care Scorecard with two of the twelve component measures being findings and
opportunities.
2e Response to Incidents and Concerns since the last Verification
Since the way in which unplanned situations are handled shows the influence of the
Responsible Care ethic and responsiveness of the management system, the team looked at
the issues, incidents and concerns that have arisen since the last verification and how the
company has handled them. Some of these may be covered under individual topics below, as
noted.
Re-verification report for BASF Canada 鈥? October 2007 Page 13 of 32
Team Findings
The company's North American 鈥淛ourney to EHS Excellence鈥? initiative is based upon their 鈥? 7-
element Health & Safety鈥? program. An indication of the importance the company places on
incident and accident reporting and analysis is that it is one of the seven elements. A
fundamental principle in the 鈥渏ourney to EHS Excellence鈥? is that of a 鈥淶ero Incident Mindset
(ZIM)鈥? and a commitment to significantly reduce injuries and incidents by a target date of
2012. This has produced a very strong attitude towards reporting and analysis and the team
found a well established and documented incident investigation and reporting process in
place. Environment, health and safety (EH&S) related incidents are covered by Performance
Standard ES-5402, security incidents are treated similarly but separately in that they must be
reported to the corporate US Security Department and the response to incidents is governed
by Performance Standard ES-5903.
The company utilizes an integrated approach to handling accidents and incidents. In North
America, the company uses an Accident Incident Module (AIM) database to record accident
or incident data. They report local as well as North America wide benefits from their system
such as easier sign-off, e-mail reminders for follow up and company wide trend analysis. The
latter allows for independent assessment of the quality of root cause investigation and the
development and implementation of specific programs to deal with existing or emerging
problem areas.
The company maintains a group of EH&S and key site and business employees trained in
root cause analysis techniques.
The North American organization distributes a weekly 鈥淓COWEEK鈥? summary of incidents of
concern whose intended audience included top North American management. Local
distribution includes a cut of Canada only data. Significant incidents are shared globally
through the double red arrow reports.
2f) Performance Measurements
The 鈥榗heck鈥? step of a management system is the part that shows the effectiveness of the
system, and a key question is: 鈥淲hat does the company check as its indicator of
performance?鈥? For a few items 鈥? emissions & wastes, occupational safety & health, incidents
related to transportation or process operations 鈥? C.C.P.A. specifies measures for reporting
under Responsible Care. Most other areas are left to the discretion of each member or
partner. The team was asked to review and comment on the measures used by the company
to track and improve performance. Some of these are covered under specific sections below,
but general comments are given here.
Team Findings
The team found a very comprehensive suite of performance measures in use by the company
and they easily satisfy the intent of this important management system element. Many of
the measures are set corporately but BASF Canada has implemented many of their own.
Management review of measures and their trending and the ability of management to make
adjustments as required was observed.
Re-verification report for BASF Canada 鈥? October 2007 Page 14 of 32
Of particular note is the Responsible Care Scorecard for manufacturing sites. It contains a
suite of twelve measures relating to Canadian Responsible Care status including two related
to community outreach. One of five levels of performance is assigned to each category for
each facility and also colour coded to emphasize current status. Although the scorecard idea
is not unique the selection of the twelve reporting areas related specifically to Responsible
Care is a best practice.
1). The Responsible Care Scorecard, because of its immediate impact in
understanding the current overall (and local) Canadian Responsible Care status is
a best practice.
The team found that the RCSC did not have review of Responsible Care related performance
measures in its mandate and would encourage them to get it included.
2). There is an opportunity for improvement for the Responsible Care Steering
Committee (RCSC) to broaden its mandate to include the review and analysis of
the suite of Responsible Care related performance measures in order to focus on
those which best satisfy the ethic of Responsible Care.
3. Team Findings for Specific Code Management Systems
In examining how the company is fulfilling the specific expectations of Responsible Care, the
team focused first on four topic areas identified as priority items by the CCPA board of
directors for the period 2005-2008. These are process safety management and the related
site emergency response, product stewardship and environmental management.
3a) Process Safety Management (PSM)
The team looked at how the hazards and risks from potential episodic ('sudden') incidents are
identified and controlled at the company鈥檚 sites, including awareness and understanding of
the methods used for assessment and the techniques for hazard control, and how these are
applied and kept current. This includes how the company鈥檚 sites rank based on the Site Self-
Assessment Tool of the Chemical Institute of Canada 鈥? whether they meet criteria for the
鈥渆ssential鈥? level of PSM, and how the company has assessed the value of aspects beyond
the essential level
Team Findings
The company has added the requirement for each facility to define their plan to advance
beyond the 鈥淓ssential鈥? level to their Responsible Care management database. Thus, this
PSM requirement has become institutionalized alongside the 151 code elements and is
managed in the same way. This is an excellent response to FRA #11 from the previous re-
verification.
Re-verification report for BASF Canada 鈥? October 2007 Page 15 of 32
Also in response to the previous re-verification, the company has trained six employees to be
able to conduct process hazard analysis (PHA) and has developed a schedule performing 12
or 13 PHAs per year covering the next eight years. The baseline PHA schedule is set by the
US Risk Management Plan (RMP) or ACC Process Safety Management (PSM) requirements.
The company uses a paper management of change (MOC) process in Canada and will
modify it to add PHA criteria now that employees are trained to perform the analysis.
3). There is an opportunity for improvement to modify the current management of
change (MOC) process to include appropriate review when a process hazard
analysis (PHA) trigger criteria has been met.
Worst Case Scenarios (WCS) were redone for all facilities using PHAST except for
Abbotsford and Georgetown where a dust explosion scenario could not be modeled using
PHAST. They have not been done for the ART facilities.
2). It is a finding requiring action to do quantitative risk assessment,
including worst case scenarios, for the Automotive Refinishing Technology
(ART) facilities in order to define the geographic scope of impact and, if
necessary, to expand the communication program to accommodate this
geographic scope.
3b) Product Stewardship
For this aspect of Responsible Care, the team examined the company鈥檚 processes for:
鈥? assessing the exposures of people to its products over their life cycles, assessing the
potential health implications of these exposures, communicating information to those
potentially affected and taking action to prevent health impacts;
鈥? ensuring that their products are not used by terrorists, the illegal drug industry or others
who might use them for illegal purposes; and
鈥? ensuring that suppliers of chemicals are meeting the intent of Responsible Care.
Team Findings
The company has built many processes to ensure that the risks associated with their products
are understood by their customers and other second parties. Customers are required to
provide self assessments for high and medium hazard products. High and some medium risk
customers receive EH&S and sales evaluations and product training seminars (e.g. Toluene
Diisocyanate (TDI) and Diphenylmethane Diisocyanate (MDI) customers receive Safe
Handling of Isocyanates Training). Similarly, distributors undergo self assessments and
audits; toll operators undergo 3rd party and BASF EH&S audits; suppliers do self
assessments; carriers and storage facility operators undergo 3rd party audits (QRC or Crop
Life) and waste contractors undergo BASF EH&S audits.
Re-verification report for BASF Canada 鈥? October 2007 Page 16 of 32
The company's Crop Protection Division has made a decision to support (in a rather large
way) involvement in their trade association, The Crop Life Institute. Through the
implementation of the many programs associated with the Institutes's stewardshipfirst(TM)
initiative the company has shown leadership in Canada in managing their products throughout
their life-cycle. These programs, listed below, set standards for members that place Canada
in the lead with respect to care and handling of agricultural chemicals.
Manufacturing Code
Warehousing Standards
Marketing Standards
Certified Crop Science Consultant
Grower Safety
Research and Development
Responsible Use and Integrated Pest Management
Material Safety Data Sheets
Container Management
Collection and Disposal of Obsolete Pesticides
Behind The Farm Gate
The company has been active on most Crop Life Institute committees but notable helped
shape the Container Management committee and was the first company to include a reminder
to growers on its package labels to recycle the package through the Crop Life Institute's
Container Management program. Roughly 70% of all containers are recycled in Canada, the
highest percentage in the world.
2). BASF's leadership in bringing ag-product container recycling to the marketplace
is a best practice.
The commitment to Product Stewardship was recently demonstrated by participation in a
multi-stakeholder, Ontario MOE sponsored initiative to improve knowledge of isocyanate
emissions from surface coating operations. BASF and others contributed their refinish
coating training facilities to conduct the experiments and they participated in the experimental
design and the analysis of results. As a result of the initiative the MOE has more accurate
isocyanate emission factors, customers have a better understanding of the requirements they
must meet to obtain a permit and subsequently the public will be better protected.
The company demonstrated, through the use of their SAP order system and transportation
procedures, how they ensure that all product shipments are destined for legitimate customers.
The company's Procurement group has an approval process for chemical suppliers but it
does not involve self assessment but rather the level of risk associated with the country of
origin of the chemical. There is no plan to include a performance based assessment
commensurate with the hazard of the chemical.
Re-verification report for BASF Canada 鈥? October 2007 Page 17 of 32
3). It is a finding requiring action that the company does not have a process
to assess and evaluate suppliers of chemical goods from a Responsible Care
perspective.
3c) Site Security & Emergency Response
The team looked at how the company had identified and assessed the security vulnerability of
its sites, and how it had selected and implemented countermeasures to address security
concerns. The team also examined how the company assesses the full range of risks its site
operations may present to their communities, together with the process for liaison with local
emergency officials at each site, and for developing, coordinating and testing site emergency
plans with those of the community.
Team Findings
Company security vulnerability assessments (SVA) have been completed and most findings
addressed in an initial surge, recently however, activity to complete the few remaining items
has fallen off although all items are in action lists.
4). It is a finding requiring action that not all items from the security
vulnerability assessments (SVA) have been completed.
All sites have good relations with local responders and have tested their site plan since the
last re-verification. Recently the Toronto site participated in a test with the West Toronto
CAER group and the Cornwall site participated in a city wide test. Windsor has had several
false alarms which provided ER Plan tests, but the team feels a documented plan for testing
should be in place. Windsor has also begun discussions on a path forward to get the local
CAER group going again and the team encourages them to follow through.
5). It is a finding requiring action at Windsor that a documented schedule for
emergency response plan testing is not in use.
4). There is an opportunity for improvement for the company to follow through on its
stated intention at the Windsor site to resurrect the CAER group in the area.
Toronto has local first responders tour the site annually, reviews the plan annually and also
tests components of their plan 3 to 4 times per year. At Cornwall the city has developed a
comprehensive ER plan that is integrated with the BASF plan. The Cornwall site manager sits
on the city emergency management committee and the site community representative is the
city ER coordinator. The city of Cornwall鈥檚 biggest concern is a chlorine trans-loading facility
near the BASF site. The BASF site hazards are low and the WCS is a site fire. In Windsor
the ER Plan has been tested, but the component relating to the dislocation of affected people
has not been fully tested and an emergency is not the time to figure out how to use the policy.
5). There is an opportunity for improvement in Windsor to provide guidance on criteria
for use, coverage, responsibilities, authorities, limits etc. for the dislocation policy.
This is a useful exercise for community related emergency response as well as
transportation emergency response.
Re-verification report for BASF Canada 鈥? October 2007 Page 18 of 32
3d) Environmental Management
In addition to examining in general the company鈥檚 performance in reducing its environmental
鈥渇ootprint, the team looked specifically at the company's performance history and 5-year
projections regarding greenhouse gas emissions. This included actions both taken and
planned, and whether through direct reduction of emissions or indirect reduction through such
measures as improved efficiency in use of energy or materials, changes in technology, etc.
For fact-finding purposes only, to assist CCPA in developing recommendations for addressing
growing concerns over water consumption, the team also reviewed any actions taken by the
company to identify and reduce its usage of water.
Team Findings
There is a comprehensive environmental management system in place with a focus on waste
streams from the plant sites as well as such customers as farmers and body shop owners.
Almost all greenhouse gas emissions are from natural gas usage at manufacturing sites.
The Canadian organization trends data on a variety of environmental issues, and each facility
has specific reduction targets, but there is no oversight nor flow-down in these measures.
6). There is an opportunity for improvement for the company to follow through on its
stated intention to conduct an energy audit at Blackie in late 2007.
6). It is a finding requiring action that BASF Canada does not have 鈥渇low-
down鈥? emission and waste reduction targets.
7). There is an opportunity for improvement for the Responsible Care Steering
Committee (RCSC) to develop an oversight role in the development and monitoring
of environmental emission and waste reduction targets.
8). There is an opportunity for improvement to move forward from 1993 as the base
reporting year in all trend charts.
9). There is an opportunity for improvement to examine the use of heat recapture
technology and/or air composting to reduce heat loss from air emission treatment at
sites where this is economically and technically practical.
Water usage is tracked but reduction plans are not in place.
In addition to examining how the company has performed in the four priority topic areas, the
team then looked into some additional selective areas of focus, as noted below.
3e) Visibility & Employee Awareness of Responsible Care
Here the team looked at how the company seeks to make Responsible Care a visible part of
its facilities and its internal and external communications, and how it ensures that all
employees understand the essence of Responsible Care and its relevance to their job
activities and decisions.
Re-verification report for BASF Canada 鈥? October 2007 Page 19 of 32
Team Findings:
The team found a very high level of employee understanding and visibility of Responsible
Care at all facilities. A significant improvement was noted at Cornwall, Responsible Care
material was visible at every corner at headquarters, and was amply visible at the Toronto
site. There are site banners and flags and in Windsor the Responsible Care logo is proudly
displayed on each and every hard hat.
The President conducts quarterly town hall meetings during site visits that are televised to all
other sites. Responsible Care is part of management review meetings both in Canada and at
an international corporate level.
The Canadian corporate training system has a Responsible Care component, both initial and
refresher which must be completed annually. This does not extend to the union employees
who receive this type of training via safety meetings.
In a walk around at the Windsor plant every employee interviewed (total of six, including one
with only one year of experience) related Responsible Care to EH&S (as expected), but also
connected it to community outreach in some manner. Good work BASF.
10). There is an opportunity for improvement for the executive contact to sign the
posted Responsible Care ethic statement.
11). There is an opportunity for improvement to update the Ecology and Safety
Policy to include the Responsible Care ethic statement instead of the old Guiding
Principles.
12). There is an opportunity for improvement to add a reference to Responsible Care
in employee brochures where this is not done already
13). There is an opportunity for improvement to post the Responsible Care
Commitment statement at the Toronto facility
14). There is an opportunity for improvement at Windsor to post an up-to-date signed
EH&S policy, Responsible Care Commitment statement, and Responsible Care
Ethic statement.
15). There is an opportunity for improvement at Windsor to include Responsible Care
as a regular agenda item for Joint Health and Safety Committee (JH&SC) meetings
and minutes.
Re-verification report for BASF Canada 鈥? October 2007 Page 20 of 32
3f) Occupational Health & Safety
The team looked at the company鈥檚 processes for continuous improvement in protecting the
safety and health of employees, contractors and visitors.
Team Findings
The basic management system for occupational health and safety is the corporate 鈥?7-element
Health & Safety Program鈥? that has been used in Canada since the early 1990's. The seven
elements are:
1. Management Commitment and Support
2. Responsibility, Authority and Accountability
3. Working Conditions to Minimize EHS Impact
4. Training
5. Incident Reporting and Analysis
6. Emergency Procedures and Programs
7. Personal Accountability
Recently in North America, BASF launched the 鈥淛ourney to EHS Excellence鈥? program which
strives to significantly improve EH&S performance 鈥? notably by the creation of a 鈥淶ero
Incident Mindset鈥? or 鈥淶IM鈥?.
In the overall scheme of things the company envisions a hierarchy of dependency with their
鈥?2015 Pillars: Sustainable Development鈥? at the top depending upon 鈥淕lobal Responsible
Care鈥?, and then 鈥淛ourney to EHS Excellence鈥?, then 鈥淩CMS鈥?, the Responsible Care
Management System and finally supporting the hierarchy is their 鈥淪even Elements鈥?. Their
鈥淛ourney鈥? involves employees transitioning from dependent, to independent and finally
arriving at interdependent. It is a very ambitious program, but one that is capable of
delivering the sought after improvement in EH&S performance.
The company realizes it has a long way to go and there are some particular situations at play
across the Canadian sites, which is increasing the difficulty of the task. Interviews at Toronto
and Windsor supported a vibrant system with good buy-in from the work force including the
JH&SC. At Toronto, hourly employees are encouraged to select the monthly safety topic and
lead the monthly safety meeting. As well,the hourly employees receive annual evaluations of
their safety performance. At Cornwall, because of the confrontational environment, the union
has withdrawn from participation on the JH&SC. The company has involved the Ministry of
Labour (MOL) in negotiations but the union is holding their ground and the MOL has given the
company permission to maintain the JH&SC process without union involvement. The
company is in discussions with recent hourly hires about becoming involved with the JH&SC.
In spite of this environment the site safety performance is good.
7). It is a finding requiring action that the Cornwall site safety work order
process is not responsive to employees submitting safety suggestions and
work orders.
3). Hourly employee involvement in selecting and leading safety meetings are an
industry best practice.
16). There is an opportunity for improvement at the Cornwall site to implement a
policy to ensure proper drum vents are utilized through out the site.
Re-verification report for BASF Canada 鈥? October 2007 Page 21 of 32
17). There is an opportunity for improvement at Cornwall to improve the
management system that ensures Material Safety Data Sheet (MSDS) copies are
current.
3g) Transportation Security
The team looked at how the company assesses the risk of deliberate misuse of products or
raw materials in transit and provides protection against such risks.
Team Findings
The team found that the company excels in this important area. The company's Distribution
Risk Assessment is updated annually and carrier and warehouse audits are completed every
two or three years. Security seals are required on incoming and outgoing bulk shipments to
BASF sites, affiliated warehouses and tollers.
3h) Risk Communications
The team reviewed the company's system for regularly assessing the full range of risks its site
operations present to their communities 鈥? from worst imaginable and worst credible scenarios
down to more likely but lower risks 鈥? and for ongoing communication to and dialogue with the
potentially affected communities.
Team Findings
The company has redone its worst case scenario calculations using the PHAST model for all
locations except Abbotsford and Georgetown where, due to the WCS being a dust explosion,
this particular modeling tool doesn't work (appropriately, the original models are still in use).
The revised scenarios, along with the updated 鈥淲hat to do in a chemical emergency鈥?
pamphlet have been shared with the Blackie, Cornwall, Toronto and Windsor communities.
Processes are in place to determine new neighbours and ensure they receive the proper risk
communication.
The management system's Responsible Care Scorecard is reviewed by senior management
and gives an immediate visual on a suite of Responsible Care measures. Two components
of the twelve relate to community outreach for each site.
ART sites have completed risk communication but have not performed the risk assessment
necessary to define the geographic scope of worst case scenario impact. This needs to be
done and the risk communication program for these sites should be expanded, if necessary,
to accommodate this geographic scope (refer to FRA #2 under PSM/Risk Assessment)
3i) Social Responsibility
The team investigated the ways the company has provided benefits to, and worked to
understand and further the social aspirations of, its local communities and broader society
beyond the boundaries of EH&S performance.
Re-verification report for BASF Canada 鈥? October 2007 Page 22 of 32
Team Findings
The company has a very strong corporate initiative in social responsibility. The German and
U.S. parents set direction, however the situation in Canada is often different and some
corporate direction (e.g. policies on diversity in the workplace) is not all that applicable here.
The Canadian organization has devoted effort to community giving and some examples of
this generosity are given at the end of this section. A policy for charitable donations (CO-
1802) guides committees, within a budget, to focus and prioritize 鈥渋n areas that leverage
commitment to science education, Environment, Health & Safety and other programs,
initiatives, and organizations that are important to the quality of life in site communities鈥?.
18). There is an opportunity for improvement to develop a separate value added
statement related to social responsibility for Canadian operations
Another example of social responsibility is the tool developed by BASF based on the concept
of eco-efficiency developed by the World Business Council For Sustainable Development.
The tool, called eco-efficiency analysis, compares processes to arrive at an end point
(product) factoring in economic and ecological efficiency, not just return on investment.
Examples of BASF Corporate and Site donation activity
The head office had grade five students sing to its employees for the Holidays and
BASF donated money to be spent towards their science program.
Adopt-a-family for the Holidays where employees donate gifts or money based on the
make-up of the family.
The Women & Business Issues group from the Windsor site was launched in 2006 and
members volunteered in the mentoring pilot project sponsored by the provincial
government with Windsor Women Working with Immigrant Women. Since, BASF
Canada was recognized with Employer Recognition Award and its diverse recruiting
strategy as well as participated in various activities supporting the program.
The Toronto, Montreal and Cornwall sites donate annually to the local Hospital.
The Blackie site donates in support of the local Canada Day celebrations and donates
to a local school for the school鈥檚 year-end celebrations. For the fourth year in row, the
site has given a Chemistry Scholarship to a Grade 12 student who obtains an 80%
average in chemistry, geology and physics and enrolls in a post secondary institution.
Windsor Site's Medical Department held a poster contest for the employee鈥檚 children to
promote, "Safety is Job 1 at BASF鈥?.
BASF Toronto and Georgetown sponsors 鈥淧lastiVan鈥? at local schools, a 鈥渟cience on
wheels鈥? van that travel throughout Canada and the United States teaching students,
educators and the public about the chemistry, history, manufacturing and
environmental issues involved with making plastics.
Some sports activities are also supported at a local level.
Robin Rotenberg was a speaker at the ECCO 2007 Environment and Energy
Conference in Toronto and at a sustainability conference in Niagara-on-the-Lake in
2007
The Windsor site has been very involved with a local public school in areas such as
environmental responsibility. They have also been involved with the University of
Windsor with site visits and talks on Responsible Care.
Re-verification report for BASF Canada 鈥? October 2007 Page 23 of 32
The Toronto site has developed a relationship with a local high school and with
Sheridan College. This has resulted in many site tours and talks on EH&S and
Responsible Care and recently a Sheridan College student consulted with employees
regarding his project examining Responsible Care and its role in Canada.
Various employee managed activities (e.g. Christmas Drive for Ernestine's Women
Shelter)
Numerous individual employee activities (e.g. Dorothy Lea Hospice, Tooney Friday for
the Parr Family Scholarship)
Miscellaneous corporate/business activity:
National Chemistry Week (CIC)
United Way 鈥? corporate donation and site campaign
Canadian Cancer Society
Science Screen Report Video series for schools in manufacturing site locations
Children's Wish Foundation
Habitat for Humanity
Daily Bread Food Bank
Donate to charity-of-request at employee's funerals
Jewish General Hospital Fund
Montreal Children's Hospital Foundation
Big Brothers and Big Sisters
William Osler Health Center
Heart and Stroke Foundation
Neighbourhood Watch
United Counties Science Fair
3j) TransCAER Outreach
TransCAER is the CCPA program for Transportation Community Awareness and Emergency
Response. It involves the company鈥檚 approach to preventing transportation incidents, its
transportation emergency response plan, and also outreach to communities through which
chemicals are transported. Company responsibilities are decided by regional TransCAER
committees formed from the members and partners in each region. The team looked at how
the company has participated in TransCAER outreach in each region where it has facilities,
and how effectively the Responsible Care ethic drives the building of relationships with
targeted stakeholder groups.
Team Findings
The company participates with its regional group (the GTA TransCAER Committee) on a
routine and regular basis and has been involved in Police Awareness Training and Safety
Training. In-depth Police Awareness Training was scheduled for late 2007.
3k) Carrier Selection
The team looked at the company鈥檚 process for establishing criteria for the selection of road,
rail, marine, pipeline and air carriers, and for ongoing assessment of those carriers against
those criteria.
Re-verification report for BASF Canada 鈥? October 2007 Page 24 of 32
Team Findings
The team reviewed how the company selects and manages tollers, marine and road carriers
and conclude that they excel in these important areas handling third party providers.
Individual provider-type (e.g. road) processes are based on the Risk Distribution Management
program and utilize specific provider-type policies (e.g. BASF Canada's Carrier Safety
Standards policy OS-7501 and similar policies for the U.S. parent). In the case of road, all
carriers in or into Canada are subject to third-party audits (QRC) on rotation. Marine carriers
must have had an assessment based on the SHIBAS questionnaire developed by the
European Chemical Distribution Institute (CDI). The company also makes shipments by air
and utilizes an approved specialized third party.
4). The company's Risk Based Distribution Management program is a best practice
3l) Engagement with Elected Officials
Since part of Responsible Care is a commitment to assist in the processes of sound public
policy development consistent with the criteria for sustainable development, the team
reviewed the company鈥檚 process for establishing ongoing relationships with elected officials
(i.e., MPs, MPPs, city councilors, etc.) in constituencies where the company has a presence,
to acquaint those officials with the nature of the company鈥檚 operations, economic impact,
Responsible Care commitment, activities and public policy concerns, and to understand the
elected officials鈥? interests and concerns. Also reviewed were the company鈥檚 engagement in
CCPA activities aimed at assisting in the development of sound public policy (e.g.,
Parliamentary Day, policy discussions, lobbying, etc.).
Team Findings
The company is guided by a policy (5416) and has participated in both Parliamentary Day and
Queen's Park day (Ontario) which have led to invitations for politicians to visit facilities in their
ridings. Site managers have included interactions with local politicians in their SCOPE report
(thus becoming a measure in the Responsible Care Scorecard report). One such interaction
has led to the passing of a private members bill (introduced by Toronto MP Roy Cullen)
making government agencies interested in collecting user fees more accountable.
3m) Community Dialogue
The team looked at how the company鈥檚 broader process for dialogue with its communities has
been working since the previous verification, including the identification of stakeholders,
community issues and concerns, how concerns were addressed and the choice of dialogue
methods. They looked at the effectiveness of the management system in ensuring the
company is planning, implementing, evaluating and continuously improving its relationship
with the community.
Team Findings
The team found that the community dialogue process is covered by a policy (5460) and is a
requirement for all sites. In Windsor they have a very comprehensive program where an
extended management group has developed a weighted-score community outreach
spreadsheet. At this site the reality of the plant location, an older mixed industrial,
commercial and residential neigbourhood, creates language, trust and transient population
barriers to efficient outreach.
Re-verification report for BASF Canada 鈥? October 2007 Page 25 of 32
Leaflets and flyers have been printed and delivered and door-to-door visits attempted. The
site is continually trying to understand and improve the effectiveness of its programs, has
used CAP and local stakeholder input and is currently investigating piggybacking its efforts on
the local neighbourhood watch program.
19). There is an opportunity for improvement for the company to follow through on its
stated intention at the Windsor site to add to its outreach activities by involvement
in the local neighbourhood watch program.
Dialogue activity is a component in the Responsible Care Scorecard and, as noted before,
updates are required quarterly for all facilities and results are reviewed by top management.
This has been an important improvement to the overall Responsible Care management
system.
20). There is an opportunity for improvement to implement a process to check that
people do know what to do in an emergency as part of the process to periodically
visit with site neighbours.
Telephone calls to folks on the contact list have generally yielded positive comments about
the company and their efforts in keeping the community informed, including the ART
(Automotive Refinishing Technology) retail facilities added to the re-verification this time
around. However, a call to the Toronto company, TransportAction, revealed the situation
where the company's former contact had retired and his replacement did not know about the
risk and what to do in an emergency.
21). There is an opportunity for improvement to have regular contact with commercial
and industrial neighbours in Toronto on risk and what to do in an emergency (and in
particular to ensure the company, TransportAction, has been communicated with).
8). It is a finding requiring action at some second party warehouses and
tollers that a community dialogue and risk communication program is not in
place. Either the second party or BASF can implement the program.
3n) Areas of Focus Identified by the Company
In addition, the company asked the team to investigate the following aspects of Responsible
Care.
Supplier, Customer and Distributor Assessments:
The company has truly excellent processes in dealing with the assessment of
customers, distributors, tollers and carriers. The team has no improvements to suggest
in this area.
The company is not doing as well with regard to suppliers. As in many large
companies the responsibility for interacting with suppliers has moved to the
procurement area where the understanding of and commitment to Responsible Care is
not as great as in those areas where chemicals are handled directly.
Re-verification report for BASF Canada 鈥? October 2007 Page 26 of 32
It will probably require agreement from upper management in the Canadian and North
American companies in defining the risk levels (that trigger performance qualification)
that will satisfy the Canadian and U.S. Association requirements.
Significant Improvements:
The team agrees that the company has made significant improvements in the following
areas (based on the list provided and for those areas where the team has sufficient
information)
Overall Responsible Care management system
Worst Case Scenarios
Global Transportation and Distribution Safety Review
Company e-newsletter
Accident/incident investigation
Best Practices
The team found four 鈥済one the extra mile鈥? or 鈥渂est practices鈥? and many examples of
excellent processes and work practices.. The ones mentioned in the report relate the
Responsible Care Scorecard, the company's leadership in ag-chemical container
recycling, hourly employee involvement in selecting and leading safety meetings, and
the company's Risk Based Distribution Management program.
We would suggest that the 鈥淛ourney to EHS Excellence鈥? is a significant and powerful
initiative that a company demonstrating the ethic of Responsible Care would implement
to make significant strides in improving EH&S performance. A job well done, but not
necessarily unique to BASF.
3o) Additional Areas Addressed During the Re-verification
None
4. Conclusion
The team was very impressed with the company's implementation of a Canadian Responsible
Care management system. They have shown an extremely positive response to the previous
re-verification and have worked diligently to integrate the Canadian system within the context
of a global Responsible Care Management System structure based on the ACC RCMS. Key
components of the Canadian management system, the Responsible Care database, the
Responsible Care Scorecard and the responsibility of the RCSC to obtain data allowing the
President to attest on an annual basis to the status of Responsible Care within the company,
will all tend to ensure the sustainability of the process and keep it self-healing. The ethic of
Responsible Care is clearly evident throughout the company and the message of Responsible
Care has clearly made its way to all levels throughout the company. It was particularly
satisfying to hear floor-level employees relate Responsible Care to, among other things,
community outreach.
Re-verification report for BASF Canada 鈥? October 2007 Page 27 of 32
The team recommends that CCPA officially recognize this re-verification with an award at the
next suitable occasion.
5. Company Comments
The process of re-verification is critical to the success of Responsible Care in BASF Canada.
It is of great benefit to have external industry experts and representatives from the community
not only confirm that our behaviours demonstrate the ethic of Responsible Care and that our
management system drives continuous improvement but to identify areas for improvement.
On behalf of BASF Canada, I would like to thank the re-verification team, including our
community representatives for their professionalism, keen interest, many suggestions and for
the thoroughness of their assessment of how we demonstrate the Responsible Care ethic and
apply the codes of practices. This report presents a fair and accurate picture of our
management systems and how BASF Canada follows the ethic.
I agree with the findings and opportunities and commit to ensure that action plans are
developed to address all findings requiring action and evaluate and address as appropriate all
opportunities for improvement.
I would also like to thank the employees of BASF Canada for continuing to live the ethic of
Responsible Care and for their hard work in continuing to make Responsible Care an integral
part of how we do business.
Robin Rotenberg,
President,
BASF Canada
Feb. 13, 2008
Re-verification report for BASF Canada 鈥? October 2007 Page 28 of 32
Appendix 1: Company Description
BASF Canada is part of the BASF Group of Ludwigshafen, Germany with regional
headquarters in New Jersey, USA. BASF Corporation is responsible for the operations of the
BASF Group in the North American region. BASF Canada is responsible for governance of
BASF's operations in Canada. It operates on a shared services platform with BASF
Corporation. BASF operates a number of different business units which report regionally into
BASF Corporation and globally into Germany. Most BASF Businesses operate by selling
through BASF Canada to Canadian customers. Some businesses are currently, or are
planning to sell directly from BASF Corporation to the customer or a distributor in Canada.
BASF Canada (BCI) is headquartered in Mississagua ON. There are six
manufacturing/distribution sites located in Abbotsford BC, Blackie AB, Cornwall, Georgetown,
Toronto and Windsor ON. Animal nutrition products are blended in the Abbotsford and
Georgetown facilities while the Cornwall facility manufacturers and distributes plasticizers, the
Winsdor facility manufacturers automotive OEM (Original Equipment Manufacturer) paint
coatings and the Toronto facility blends polyurethanes and operates a general distribution
center.
BASF Canada is the owner of Automotive Refinish Technologies, Inc. (ART) in Canada.
ART operates a chain of 7 stores that sell BASF automotive refinish coatings and other 3rd
party coatings related supplies (sand paper, body filler, mixing equipment, etc.) to auto body
shops. ART is operated out of the BASF Coatings business, based in Southfield, Michigan.
The ART facilities in Canada are located in Winnipeg MB, Quebec City and Laval QC and
Belleville, Mississauga and Windsor, ON.
BASF Canada is also the owner of BASF Construction Chemicals Canada Ltd (BCCC).
BCCC is formerly Degussa Construction Chemicals Canada Ltd. which was acquired in July
2006. This business is run from Cleveland, Ohio. The BCCC facilities in Canada are located
in Nisku AB, Montreal QC and Brampton and Mississauga ON.
The company has an Crop Protection Division office in Winnipeg MB, a research facility in
Saskatoon SK and research farms in Regina SK, Edmonton and Lethbridge AB, Reinfeld MB
and London and Westminister ON.
Re-verification report for BASF Canada 鈥? October 2007 Page 29 of 32
Appendix 2: Team and Contacts
This section identifies:
鈥? the members of the verification team, including community reps.(unless shown in the
body of the report);
Name Affiliation Representing
Gerry Whitcombe C.C.P.A. verifier Industry (team leader)*
Cam Dillabough C.C.P.A. verifier Industry*
David Powell C.C.P.A. verifier Community at large*
Lisa Harvey Community representative Cornwall local community
Zig Maleszewski Community representative Toronto local community
Leslie Chaif Community representative Windsor local community
Team members assigned by C.C.P.A. are shown by an asterisk (*).
the persons contacted during the verification, both inside and outside the company;
Name Position
Robin Rotenberg President, BASF Canada
David Peters Manager, EHS and Responsible Care
Patty Vandierendonck R&D code coordinator
Barry Nicholas Manufacturing Co-CAER code coordinator, Toronto site manager
Ivan Videc Transportation and Co-Distribution code coordinator
Kerry Bowman Business Representative 鈥? Co-Distribution code coordinator
Martine Despatie Communications 鈥? Co-CAER code coordinator
Tom Vandemoortele Hazardous Waste code coordinator
Katrina Gabriel Transportation code coordinator (future)
Wayne Barton Field Biology Manager, APN
Kent Jennings Toxicology and Biotechnology Manager, APN
Bob Bradshaw Toll Manufacturing and New Product Development Leader, APN
Greg Elkins North America Logistics Transportation Manager
Greg Buza Global Marine/North America Rail Manager, BASF Corporation
Mike Georgescu Plant Engineer, Toronto
Greg Gardin Site R&D Code Coordinator, Toronto
Jeff Wildman Operations Manager, ART and bodyshopmall.com
Mary Cormier Regional Operations Manager , ART
Pete Carter Branch Operations Manager , ART
David Sinclair Production Manager, Windsor
Dean Clevett T.E.S. Manager, Windsor
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Mark Thibeault EH&S Team Member, Windsor
Adam Bickel Michigan/Canada EHS Hub Manager
Edwin Kwan Lap Tam Assistant Dean, Student Affairs, University of Windsor
Justin Durham Employee, Windsor
Mike Rosella Employee, Windsor
Terry Harrison Employee, Windsor
Eli Lyons Employee, Windsor
Maria Stojanov Employee, Windsor
Christina Zemlak Employee, Windsor
Jeff Meloche Employee, Windsor
Thuy Dao Employee JH&SC rep, Windsor
Paul Shank Employee JH&SC rep, Windsor
Rob Slikboer Employee JH&SC rep, Windsor
Scott MacDonald Employee JH&SC rep, Windsor
Brian Shuttleworth Employee JH&SC rep, Windsor
Brian Charron Employee JH&SC rep, Windsor
鈥? A brief summary of the process by which the information was obtained:
The re-verification took place over several days during August, September and October,
2007. On August 21 the re-verification team (3 members) held a planning meeting in Toronto,
Ontario. The purpose of the meeting was for team building, for review of the information
package, to meet with the principal re-verification contact. During our meeting with the
company contact we established which sites would be visited and who would be interviewed.
The first day of the re-verification was Thursday September 20, 2007. One member of the
CCPA Team (the industry representative from the previous re-verification) augmented by the
local community representative met with the Overall Coordinator and plant representatives in
Cornwall ON.
Days 2 and 3 were held in Toronto and Mississauga on October 2 and 3, 2007, where the
industry representative, the community-at-large representative and the local community
representative met with the Canadian President and senior company representatives and
visited facility sites. The team leader had taken ill and unfortunately had to participate by
teleconference.
On the final day (October 4, 2007) the venue moved to Windsor ON. Here the team leader
and the community-at-large representative augmented by the local community representative
met with the Overall Responsible Care coordinator and facility representatives and visited the
site and met with employees. The team had lunch with members of the plant JH&SC.
Re-verification report for BASF Canada 鈥? October 2007 Page 31 of 32
Acronyms Used In This Report
ACC 鈥? American Chemistry Council
AIM 鈥? Accident Incident Module
ART 鈥? Automotive Refinish Technology
BP 鈥? Best Practices
CAER 鈥? Community Awareness Emergency Response
CBT 鈥? Canadian Business Team
CCPA 鈥? Canadian Chemical Producers' Association鈥檚
CDI 鈥? Chemical Distribution Institute
CEC 鈥? Canadian Executive Committee
CEO 鈥? Chief Executive Officer
DRT 鈥? Direct Reports Team
EH&S 鈥? Environment, Health and Safety
EHS 鈥? Environment, Health, Safety
ER 鈥? Emergency Response
FRA 鈥? Finding Requiring Action
GTA 鈥? Greater Toronto Area
JH&SC 鈥? Joint Health and Safety Committee
JHSC 鈥? Joint Health Safety Committee
MOC 鈥? Management Of Change
MOE 鈥? Ministry of the Environmental
MSDS 鈥? Material Safety Data Sheet
OFI 鈥? Opportunity For Improvement
PDCA 鈥? Plan, Do, Check, Act
PHA 鈥? Process Hazard Analysis
PHAST 鈥? Process Hazard Analysis Software Tool
PSM 鈥? Process Safety Management
RC 鈥? Responsible Care
RCMS 鈥? Responsible Care Management System
RCSC 鈥? Responsible Care Steering Committee
RMP 鈥? Risk Management Plan
SCOPE 鈥? System for Community Outreach Planning and Outreach
SVA 鈥? Security Vulnerability Assessment
WCS 鈥? Worst Case Scenarios
ZIM 鈥? Zero Incident Mindset
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