responsible care - Chemistry Industry Association of Canada

Transcription

RESPONSIBLE CARE®
Verification Report
Shell Chemicals Canada Inc.
January 10 - 17, 2011
Disclaimer
This report has been produced by a team, convened by the Chemistry Industry Association of
Canada (CIAC), to provide advice to the member-company and assist it in meeting its
Responsible Care® commitments. The material in this report reflects the team's best judgment in
light of the information available to it at the time of preparation. It is the responsibility of the
CIAC member-company that is the subject of this report to interpret and act on the report’s
findings and recommendations 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 CIAC members are expected to share the results of this guidance
document with interested parties, the Association, its member-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.
Responsible Care® is a registered trademark of the Chemistry Industry Association of
Canada.
EXECUTIVE SUMMARY AND TEAM CONCLUSIONS
This report documents the observations and conclusions of the independent verification team tasked
with conducting a Responsible Care Verification of Shell Chemicals Canada Limited (SCCL). The
verification was carried out between January 10 and 17, 2011. It included team visits to SCCL’S
corporate headquarters in Calgary, Alberta and manufacturing site visits in Scotford, Alberta and
Sarnia, Ontario. This was the fifth Responsible Care verification completed for Shell Chemicals in
Canada.
As a result of the examination conducted, the verification team is of the opinion that the Responsible
Care Ethic and Principles for Sustainability are guiding company decisions and actions, and that a
self-healing management system is in place to drive continual improvement. The verification is
complete and no further involvement is required by the verification team.
Notwithstanding the above, the re-verification team found that SCCL’s overall Responsible Care
Management system had become less clearly defined since the 2007 Re-verification as a result of
the significant organizational alignment, personnel, and role changes that have occurred since that
time. However, SCCL’s Corporate Management in Calgary along with Shell’s Manufacturing Site
Management at both Scotford and Sarnia were found to be very committed to Responsible Care. The
team believes that the company is capable of responding to the range of Findings Requiring Action
identified during the verification - summarized below and discussed in detail in the report.
The re-verification team recommends that the CIAC officially recognize this re-verification with an
award at the next suitable occasion.
Date: April 19, 2011
Signed:
Verification Team Leader
For more information on this or on the company’s original report for verification of Responsible Carein-Place, please contact your local company site or the company’s overall Responsible Care
coordinator:
Mike Drumm
(403) 691-4191
[email protected]
Responsible Care Verification Report for Shell Chemicals Canada Inc.
Page 2 of 28
Summary of Verification Team Observations
Following is a listing of all Findings Requiring Action, Best Practices / Extra Miles and Opportunities
for Improvement, found in the body of the text. In all, the team recorded 2 findings and 16
Opportunities for Improvement. Progress on action to resolve the Findings will require follow-up at
each Leadership Group Meeting, with the local communities, in the company’s annual CEO recommitment to CCPA and, along with the decisions pertaining to the Opportunities, in the next
Responsible Care re-verification. 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’s intent.
Findings Requiring Action:
 It is a finding requiring action that an assurance process be established to ensure that
detailed Canadian Responsible Care code requirements and expectations are being met on
an ongoing basis, including services provided to SCCL by other Shell entities e.g. SCAI in
Calgary, the Shell Chemicals Plants in Scotford and Sarnia.
 It is a finding requiring action that the company ensures that third party contracted
terminals apply the intent of the Manufacturing Code of Practice, where Shell owned
material is located. The processes that are built to handle these requirements must be
documented, current, robust, and subject to critical review. One expected outcome of this
analysis would be that there are requirements in writing to ensure that contracted
terminals, etc., have an ongoing dialogue process with the potentially impacted local
community (including residential neighbours) and emergency responders about the
hazard/risks of stored materials.
Best Practices/Extra Miles:
 The Scotford site process to test, through to its conclusion, their community emergency call
system to potentially impacted neighbours.
 Rolling out of the Hearts and Minds behaviour based safety program to terminals and carriers.
 Coaching product handling terminals in the “Learnings from Incidents” process which uses
information from a Shell corporate database to identify learning opportunities.
 The “Goal Zero” initiative with “12 Life Saving” and “3 Golden” Rules.
 Tracking and visibly displaying the number of days since the last “Goal Zero” incident.
 The “Journey Management Plan” travel safety initiative.
 The Scotford site “ground truthing” process through which approximately 70 stakeholders located
within a five km radius of the site are visited every two years.
Opportunities for Improvement:
 The Team suggests that SCCL reviews its management of organizational change process for
positions with Responsible Care responsibilities to improve the continuity of coverage during
personnel and/or organizational changes.
 Reference Canadian Responsible Care components in appropriate Shell management system
documents to ensure that Responsible Care requirements and expectations are addressed on an
ongoing basis...
 At all facilities, identify all affected stakeholders for communication of re-verification reports (e.g.,
local neighbours, emergency services. local government, etc.), not only residential neighbours.
 Establish a formal reporting system between Manufacturing and Corporate Operations for
addressing Responsible Care Re-verification report follow up items. FAM, as a tool, could be
helpful in this regard.
Page 3 of 28












Compare performance results with CIAC peer results to identify areas of strength and learning
opportunities in others.
Perform a process safety self assessment for the Sarnia chemicals site vs. the Site Self
Assessment Tool to identify any gaps in comparison with standard industry benchmarks and to
develop and implement improvement action plans where warranted.
Have a process in place to ensure that process safety Site Self Assessments are maintained
current.
Build links from hazard assessment processes to the communications process for community
dialogue to ensure that most appropriate Worst and Credible case scenario results are available
for presentation to the public.
Similar to the Scotford model, the Sarnia site should establish a process to test, through to its
conclusion, the community emergency call system to potentially impacted neighbours (i.e., not
just a test of the call system technology but to check that people have actually been contacted
and advised what to do).
Establish a cross reference between site and CIAC emergency response expectations.
Expand the awareness of Responsible Care by including educational/promotional materials in the
customer and reseller visit template.
The Scotford site is encouraged to perform a site wide water usage study to identify, prioritize
and implement usage reduction, reuse and recycle initiatives as currently planned.
To enhance awareness of Responsible Care, it is suggested that, in communications with all
employees at the Scotford and Sarnia sites, Responsible Care be positioned as the “lens” the
public uses to view a company that enables them to view all CIAC companies the same way.
With Shell Chemicals being a CIAC member, it is Shell’s responsibility is to ensure that all
Responsible Care expectations are embedded into company systems. Note- Displaying
Responsible Care as an umbrella is a useful visual aid.
With global Shell leadership gaining increased awareness of Responsible Care and CIAC having
increased Responsible Care promotional expectations for member companies, SCCL are
encouraged to challenge corporate restrictions which inhibit their ability to include Responsible
Care on commercial documentation business cards and other promotional materials.
Promote the “Life in the Heartland” group’s existence and role in risk communications to
stakeholders within their targeted service area...
Document the community outreach processes while ensuring that CAER code expectations are
included.
INTRODUCTION AND OVERVIEW
1a)
The company
This is the report by the verification team on those operations of Shell Chemicals Canada Ltd. which
are covered by the company’s commitment to the Responsible Care initiative of the Chemistry
Industry Association of Canada. 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 Chemistry Industry Association of Canada (CIAC) by which
the association’s 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 – an approach which started in Canada but has since spread to over 45
countries around the world.
Page 4 of 28
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:
 We are stewards of our products and services during their life cycles in order to
protect people and the environment.
 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.
 We respect all people.
 We work together to improve continuously.
 We work for effective laws and standards, and will meet or exceed them in letter
and spirit.
 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’ 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 CIAC web site www.canadianchemistry.ca
(click on the tab for Responsible Care).
1c)
Expectations of CIAC members and partners
Each CIAC 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 CIAC, 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 “Responsible Care-in-Place”. 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’s 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’s 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’s peers in CIAC and the public, the existence of a companywide 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.
Page 5 of 28
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’s operations. This is known as reverification.
Each verification is conducted by a team consisting of:
 knowledgeable industry experts with experience in Responsible Care;
 a representative of the public at large (usually with a public interest background and with
experience in Responsible Care gained from serving on the CIAC’s national advisory panel) and
 one or more representatives of the local communities where the company’s facilities are located.
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 “top-down” rather than the “bottom-up” 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:
 does the organization have an effective management system in place to ensure understanding of
Responsible Care?
 what is the process to determine and communicate the acceptable level of performance?
 what is the process for assessing the performance of the system and effecting follow-up to meet
or exceed the acceptable level of performance?
 what is the process for ensuring up-to-date documentation?
 do sufficient resources appear to be, or are thought by employees to be, in place?
The findings are summarized in a report which highlights:
 actions required by the team before they consider the company meets the expectations of
Responsible Care;
 opportunities for improvement, which are recommended but not mandatory;
 recognition of any exemplary practices of the company which could be a model for other CIAC
members.
The report is given to the company and CIAC, 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 CIAC in writing when these have been met to their
satisfaction.
Responsible Care-in-Place verification of Shell Chemicals Canada Ltd.
Company name at time: Shell Chemicals Canada Ltd.
Date of verification (visit): November 28 – 30, 1995
Locations visited: Calgary and Scotford Alberta. Distribution Centers in Burnaby BC, Sarnia Ontario,
Toronto Ontario, and Montreal Quebec were included in the scope by telephone.
Page 6 of 28
Team follow-up needed:
No
Date of final sign-off: June 18, 1996
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 2 of this re-verification
report.
1d)
ii) Re-verification
Approximately every three years after team acceptance of Responsible Care-in-Place, the CIAC
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.
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’s
management systems in applying the ethical principles throughout the company’s 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 PlanDo-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 – customers, transporters, etc. – 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’s way of doing business, including awareness of Responsible Care and its implications
among the company’s employees. The examination then progresses into a broad-ranging review of
the company’s management systems for Responsible Care, with a special investigation into certain
topics highlighted by CIAC in the verification protocol.
The team looks at how effectively the company’s 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
Page 7 of 28
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.
Most recent previous Responsible Care Re-verification of Shell Chemicals Canada Ltd.
Company name at time: Shell Chemicals Canada Ltd.
Date of re-verification (visit): November 13-15, 2007
Locations visited: Corporate Office at Calgary, Alberta; and Manufacturing Facility at Scotford,
Alberta
Team follow-up needed: No
Date of final sign-off: February 7, 2008
The report below presents the findings of the team from this re-verification of Shell Chemicals
Canada Ltd. 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 CIAC 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, Opportunities for Improvement (recommended but not
considered mandatory) are shown in italics, while Best Practices are shown underlined).
2.
GENERAL FINDINGS OF THE TEAM
2a)
Statement on the Responsible Care 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’s judgement, decisions and actions.
FINDINGS
Overview:
The team found that the Responsible Care® ethic is well understood guides the actions and
decisions of the President of Shell Chemicals Canada Ltd, who is also the CCPA Executive Contact,
and is evident in the individual behaviours and practices observed throughout the organization.
The company is actively engaged with its key stakeholders, and sees Responsible Care as being
that which must be done every day to maintain its “licence” to operate with those stakeholders.
A new Responsible Care Ethic and Principles for Sustainability have recently been developed by the
CIAC. A fact-finding questionnaire in this regard has been completed by the company. This is
included as Appendix 3 to this report.
2b)
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 - review code requirements
Page 8 of 28
- Benchmark best practices
- get input from stakeholders
- decide on best approach
- set targets for performance
- assign responsibility
Do
- document
- train people
- assign resources
- carry out activities
Check- audit
- Measure performance of system
- Measure performance from system
- obtain stakeholders’ feedback
- assess employees’ performance
Act
- follow-up on audit findings
- communicate performance, get feedback
- reward or correct employees
- repeat Plan steps
There must be such management systems both for the overall management of the company and for
each code element. This section 2.3 covers the team’s findings with respect to this overall
management system, and section 3 below covers the specific code elements that were reviewed in
the re-verification.
FINDINGS
Overview:
The Shell Global Health Safety and Environment Policy requires that every Shell company has a
systematic approach to health, safety and environmental management, that is designed to ensure
compliance with the law and achieve continual performance improvement through a Plan-Do-CheckAct cycle.
In 2006, a single Health, Safety, Security and Environment Management System was developed to
replace previous systems. It provides a structured and documented framework for the management
of health, safety, security and environment across all company operational and support staff
activities and also defines how the company meets its Product Stewardship and Responsible Care
commitments. The management system has been certified against an international management
system standard for health and safety referred to as OHSAS 18001, an Occupation Health and
Safety Assessment Series intended to help organizations control occupational health and safety
risks.
Health, safety, security and environment strategic objectives are initiated through the company’s
functional support staff and proposed to the operational leadership team for review and support. The
strategic objectives are supported by a number of key performance indicators and strategic
programs. In addition to adopting these corporate initiatives, additional targets may be established at
subsequent levels of the organization to address specific business and local risk management
objectives.
The company considers audits as important mechanisms for assessing the adequacy of health,
safety, security and environmental processes, systems and management controls and for identifying
areas for improvement, as well as verifying compliance with applicable laws and regulations, policy,
Page 9 of 28
standards, and Responsible Care requirements. The company’s audit programs are risk-based and
conducted on defined frequencies. These programs include independent audits of the management
system, annual self-assessments, and risk appraisals of third-party operations in the supply-chain,
such as customers and contractors.
Areas being audited are accountable for developing and implementing a remedial action plan to
address recommended actions. Closure of the actions is tracked against agreed target dates using a
formalized action tracking system. The status of open action items is reviewed by management on a
quarterly basis. Any overdue actions are taken into account as part of key performance indicators
covering overdue corrective actions.
The responsibility for ensuring follow up and closure of any findings from risk appraisals of third-party
operations rests with the appropriate sales leadership (for customer appraisals) and contract
management (for contractor appraisals). Progress against action plans to close any findings is
reviewed on a quarterly basis by the appropriate leadership, along with the progress of executing
appraisals against plans.
At the Scotford and Sarnia facilities, a risk-based approach is taken to the implementation of the
company’s Health, Safety, Security and Environment Management System. This includes
identification all related site risks and the establishment of controls to mitigate these risks. A
comprehensive training plan and tracking system is in place to ensure employees and contractors
are aware of site hazards and how to address these in their day-to-day activities. During the
operational integration of Shell Chemicals and the adjacent Shell Refinery at Scotford, the company
adopted best practices for both complexes.
Canadian Responsible Care Codes were cross mapped to Shell’s Management System (MMS) at the
time of the 2007 re-verification but this reference could not be located during the preparatory stage
of this re-verification. It was also found that, with the change in organizational personnel and
reporting alignments, there was a lack of clarity of roles, responsibilities and reporting systems
between SCCL and the manufacturing sites regarding Responsible Care as SCCL prepared for this
Re-verification... It was also found that Management Systems in place no longer included a validation
process for the CIAC executive contact’s annual attestation to CIAC regarding Responsible Care.
The observations above were discussed with the CIAC executive contact and the Shell
Manufacturing General Managers at both sites. All were in agreement that an improved Responsible
Care oversight process was warranted. An option used by several other CIAC members is to have a
Responsible Care and Sustainability sub-committee of the Corporate Board. If Shell were to use this
approach, it appears that the SCCL President, both site Shell Manufacturing General Managers, the
Product Stewardship Manager and the overall Responsible Care Coordinator should be core
members with others such as site Coordinators, Contract Managers etc participating as warranted to
ensure coverage of all Responsible Care code areas. .
FINDINGS REQUIRING ACTION:
i) It is a finding requiring action that an assurance process be established to ensure that
detailed Canadian Responsible Care code requirements and expectations are being met on
an ongoing basis, including services provided to SCCL by other Shell entities e.g. SCAI in
Calgary, the Shell Chemicals Plants in Scotford and Sarnia.
i) The Team suggests that SCCL reviews its management of organizational change process for
positions with Responsible Care responsibilities to improve the continuity of coverage during
personnel and/or organizational changes.
Page 10 of 28
ii) Reference Canadian Responsible Care components in appropriate Shell management system
documents to ensure that Responsible Care requirements and expectations are addressed on an
ongoing basis...
2c)
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.
FINDINGS
Overview:
During the last verification there was one finding requiring action and twenty three improvement
opportunities identified. These were sorted, with Shell Manufacturing assuming responsibility for
those within their scope and SCCL the rest. While the Re-verification team found that all accepted
items had been prioritized and tracked using a remedial action plan to 100% closure, there was no
ongoing tracking and reporting of the overall status to the CIAC Executive Contact.
The 2007 re- verification report results were communicated in the Scotford area using the local
community paper media, as well as posting on the Shell Chemicals Scotford public website.
www.shell.com/scotfordchem
i) At all facilities, identify all affected stakeholders for communication of re-verification reports (e.g.,
local neighbours, emergency services. local government, etc.), not only residential neighbours.
ii) Establish a formal reporting system between Manufacturing and Corporate Operations for
addressing Responsible Care Re-verification report follow up items. FAM, as a tool, could be
helpful in this regard.
2d)
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.
FINDINGS
Overview:
A structured incident management and reporting system is in place in all Shell Chemicals
businesses. At Scotford and Sarnia, incidents are tracked and managed using an online database,
FIM (Fountain Incident Management). SCAI in Calgary reports transportation and customer incidents
using FIM and work with customers and carriers to understand underlying causes and to track
corrective actions.
The Scotford Site Coordination Team meets each morning to review new incident/near miss inputs to
the FIM database with the ownership of specific items being assigned. e.g.; with the Unit Manager if
for an operating area. The Qualitative Risk Assessment Matrix (RAM) process is used to classify
items into one of three levels that define the depth of investigation required. The FIM system is then
used to track follow up items through completion with adherence to completion targets being very
high due to the high profile exceptions receive. For medium and high level RAM incidents, there is a
follow up system to help ensure that actions taken resolve incident root causes. There is also a
Page 11 of 28
“check” step in the process to ensure that learning incidents are shared with other Shell
manufacturing locations.
The Company uses a Public Concern Form and Public Concern procedures when dealing with public
concerns/complaints. Complaints/concerns where the Company is the source are tracked in the
online FIM database and included in site HSSE stats.
2e)
Performance Measures
The ‘check’ step of a management system is the part that shows the effectiveness of the system,
and a key question is: “What does the company check as its indicator of performance?” For a few
items – emissions & wastes, occupational safety & health, incidents related to transportation or
process operations – CIAC 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.
FINDINGS
Overview:
Performance objectives and target setting and tracking requirements are outlined in the Health,
Safety, Security and Environment Management System and then reported on and updated quarterly.
The following represents the company’s regulatory and industry reporting requirements, as well as
measures that have been developed to assess ongoing performance.







Federal Government Reporting:
 National Pollutant Release Inventory
CCPA Reporting:
 Emissions and wastes
 Transportation Incidents
 Occupational illnesses and injuries
 Process related incidents
Employees/Long Term Contractors Health & Safety:
 Lost time injury frequency
 Total recordable injury frequency
 Lost time occupational illness frequency
Near Miss Incidents
Preventable Vehicle Accidents
Environment
 Regulatory fines or charges
 Complaints (noise, odours, traffic)
 Compliance incidents (permit exceedances/reportable spills)
 Spills (> 1 Litre at manufacturing facilities/ transportation)
Loss of primary containment
In addition to the above, community concerns are tracked and there are on-going efforts to minimize
the impact of company operations on local communities.
Page 12 of 28
Performance for each Shell manufacturing site vs. various metrics is tracked globally with specific
site results vs others being available for comparison purposes. Both the Sarnia and Scotford sites
contribute data to satisfy CIAC reporting requirements but SCCL don’t compare their results with
CIAC peers.
Opportunity for Improvement:
i) Compare performance results with CIAC peer results to identify areas of strength and learning
opportunities in others.
3.
TEAM FINDINGS FOR SPECIFIC CODE MANAGEMENT SYSTEMS
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’s 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’s sites rank based on the CIAC High Inventory Site
Assessment Tool – whether they meet criteria for the “essential” level of PSM, and how the company
has assessed the value of aspects beyond the essential level –
FINDINGS
Overview:
Worst imaginable case incident scenarios have been identified for both sites as well as those
scenarios which may be considered as more credible with respect to their likelihood. These are
periodically evaluated and are revised as standards or models change.
There is a comprehensive process safety program in place which addresses risk assessment, hazard
reviews, reactive chemicals reviews, equipment integrity, loss prevention, regulatory requirements,
hazards awareness, community awareness and emergency response, management of change,
incident and near miss tracking, and auditing. Human errors are included in the risk assessment
process.
The most recently completed process safety self assessment for the Scotford site, using the Site
Self-Assessment Tool of the Chemical Institute of Canada was completed in July 2007. The resultant
ranking was at the “Excellent” level, two levels above the “Essential” level required by the CIAC.
There was no indication of this type of assessment having been performed for the Sarnia site.
i) Perform a process safety self assessment for the Sarnia chemicals site vs. the Site Self
Assessment Tool to identify any gaps in comparison with standard industry benchmarks and to
develop and implement improvement action plans where warranted.
ii) Have a process in place to ensure that process safety Site Self Assessments are maintained
current.
iii) Build links from hazard assessment processes to the communications process for community
dialogue to ensure that most appropriate Worst and Credible case scenario results are available
for presentation to the public.
3b)
Site Security & Emergency Response
Page 13 of 28
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.
FINDINGS
Overview:
Shell has dedicated Security staff that monitor security developments and help ensure Shell
Chemicals responds accordingly. In 2007, Scotford completed a site Security assessment against
the detailed Shell downstream Security requirements. Gaps were identified and corrective actions
implemented. In addition, Shell Chemicals actively monitors the developments and activities of its US
sister company and respond accordingly to any actions that fall out of these for Canada.
In its January 2010 re-validation report, the US Department of Homeland security recognized SCCL’s
best practice for security on computers (use of key cards with password for personal access).
Emergency response plans including Business Continuity and Disaster Recovery Plans are in place
for the Scotford and Sarnia plant sites and for its service provider SCAI as per the requirements of
Shell’s HSSE MS and as part of global Shell Chemicals Crisis management plans. Emergency plans
follow the ICS unified command philosophy. Tier 1 and Tier 2 responses are managed locally with
outside expertise as required. Tier 3 incidents are managed under the Shell Chemicals corporate
umbrella with the Crisis Management team supported by Shell Canada and the regional Shell
Chemical organization (USA).
Shell Sarnia is part of the Chemical Valley Emergency Coordinating Organization. In the event of an
incident, CVECO is notified and proceeds with public notification as necessary. Shell participates in
the annual Sarnia Area Disaster Simulation (SADS) exercise and also has a community notification
line in place with the outgoing message being updated during emergency situations and/or unusual
site activity.
The Scotford site, to notify the public when they are required to take public safety actions such as
Shelter in Place, utilize their site Shell Notification System (SNS) which is able call their entire call out
zone within seconds. It is the same system used by Homeland Security in the US. The site also tests
their community notification system annually, sending out a letter out prior to their test call out to
advise neighbours of the upcoming test and to ask residents to advise Shell of telephone number
changes.over the last year. The call out report generated after the test allows Shell to see which
specific residents confirmed that they received the test call out. This report is then reviewed to check
if any phone numbers have been disconnected, etc. The results of the test call out are then reported
out to the neighbours in a letter. The Scotford site are also a member of an organization referred to
as the Northeast Region Community Awareness Emergency Response (NRCAER) group, which is a
regional mutual aid emergency response association established to coordinate the sharing of
emergency response resources, personnel and services available in the region. There is also a call
out system that Northeast Region Community Awareness Emergency Response members can use
to provide residents with information about more serious (non-emergency) incidents. Their call out
system supports the municipal and provincial notification systems used to convey emergency and
safety information to residents.
Regular drills are carried out for on site and community emergency scenarios at the Scotford and
Sarnia sites.
Page 14 of 28
Emergency response leaders interviewed during the re-verification were unaware of CIAC’s
Responsible Care requirements. This doesn’t mean that they don’t comply, just that they were
unaware of their status.
Best Practice:
i) The Scotford site process to test, through to its conclusion, their community emergency call
system to potentially impacted neighbours.
i) Similar to the Scotford model, the Sarnia site should establish a process to test, through to its
conclusion, the community emergency call system to potentially impacted neighbours (i.e., not
just a test of the call system technology but to check that people have actually been contacted
and advised what to do).
ii) Establish a cross reference between site and CIAC emergency response expectations.
3c)
Product Stewardship
For this aspect of Responsible Care, the team examined the company’s processes for 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; ensuring that their products are not used by terrorists, the illegal drug
industry or others who might use them for illegal purposes; and ensuring that suppliers of chemicals
are meeting the intent of Responsible Care.
FINDINGS
Overview:
At the concept phase of a new product development, Shell has a global requirement that the product
must undergo a sustainability review. These reviews have been carried out for styrene, isopropyl
alcohol, and ethylene glycol. This process identifies any major health, safety or environmental issues
that may negate products beneficial impacts and force a go or no go decision to proceed with the
development.
In addition, once the product is approved for introduction, the project must undergo a health, safety
and environmental assessment, scaled to the activity under review, for the following situations:
 New facilities, new processes, new or changing business practices;
 Major assets disposed of or obtained;
 Changes to existing facilities or processes (e.g. plant change);
 Production or marketing of new or modified products;
 Use of new raw materials including treatment chemicals and catalysts;
 Decommissioning or reclamation activities; and
 Other business activities which may have significant health, safety or environmental impacts.
These health, safety and environmental assessments must be done prior to proceeding with the
activity. The assessment identifies and assesses all potential impacts including health effects and is
an integral part of the economic and health, safety and environmental decision-making process. It
identifies, from the list of potential impacts, the health, safety or environmental critical design and
operation variables and establishes design targets and business controls for each variable. These
controls are then factored into the design and costing of the project.
Page 15 of 28
The assessments include review of the potential impacts on biodiversity, prior to all new activities and
significant modifications to existing ones. They bring focused attention to the management of
activities in recognized environmentally sensitive situations. Key stakeholders in these areas are
identified early on in the process and consulted.
The company introduced a product “banding” process in 2006. Criteria examined include health,
reactivity, flammability and environmental, to provide an overall banding color classification for the
particular product. This process includes steps to assess if there are any potential health issues not
addressed in current scientific data.
Strict protocols are used for the review and acceptance of new customers. The cycle of ongoing
customer assessments has been changed where warranted to meet requirements of the color
banding process with self-assessments being required at three-year intervals. Quarterly customer
visits include HS& E performance discussions. Motor Carrier drivers are involved as ‘eyes and ears”
when at customer facilities with the feedback used as input to the customer evaluation process.
Shell Chemicals has developed Storage & Handling HSSE minimum requirements and hold formal
Contractor Business Performance Reviews using a recently updated assessment document.
i.
FINDING REQUIRING ACTION:
It is a finding requiring action that the company ensures that third party contracted
terminals apply the intent of the Manufacturing Code of Practice, where Shell owned
material is located. The processes that are built to handle these requirements must be
documented, current, robust, and subject to critical review. One expected outcome of this
analysis would be that there are requirements in writing to ensure that contracted
terminals, etc., have an ongoing dialogue process with the potentially impacted local
community (including residential neighbours) and emergency responders about the
hazard/risks of stored materials.
Best Practices:
i) Rolling out of the Hearts and Minds behaviour based safety program to terminals and carriers.
ii) Coaching product handling terminals in the “Learnings from Incidents” process which uses
information from a Shell corporate database to identify learning opportunities.
i) Expand the awareness of Responsible Care by including educational/promotional materials in the
customer and reseller visit template.
3d)
Environmental Management
In addition to examining in general the company’s performance in reducing its environmental
“footprint, 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 CIAC 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.
FINDINGS
Overview:
Page 16 of 28
Shell Global Environmental Standards require that all major Shell installations, including company’s
facilities at Scotford and Sarnia, have an environmental management system certified against a
recognized independent system standard. The company’s management system has therefore been
certified against the International Organization for Standardization’s standard ISO 14001, entitled
“Environmental management systems - Requirements with guidance for use”.
Shell Scotford is committed to manage provincial and federal GHG intensity reduction requirements.
Energy and GHG management is the accountability of their Hydrocarbon Management Group. Shell
Chemicals will be participating in a Scotford Complex Water Use Study which is tasked with
minimizing site water use and maximizing re-use by using synergies with the Scotford Upgrader,
Upgrader Expansion, Refinery and Chemicals plants. A high percentage of the carbon dioxide (CO2)
from the Monoethylene Glycol (MEG) unit is pipelined to near neighbour Air Liquide for ultimate
usage in such diverse applications as enhanced oil recovery and by medical customers.
The direct emission of greenhouse gas from the Sarnia Chemical Plant is a minor environmental
aspect. The management of indirect emissions, by reducing energy, is carried out on a site wide
basis and the Chemical Plant apportionment is commensurate with its relative size and the
identification of opportunities.
The Sarnia Chemical plant operates a cooling water tower to reuse water, instead of a once-through
system as used elsewhere in the manufacturing centre. Cooling water and steam use was reduced
by the shutdown of the polypropylene manufacturing facility. There is a clear focus evident on
reducing the impact of company operations on the environment.
i) The Scotford site is encouraged to perform a site wide water usage study to identify, prioritize
and implement usage reduction, reuse and recycle initiatives as currently planned.
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.
FINDINGS
Overview:
There was a general awareness of Responsible Care among employees and those who were
contacted were able to relate the essence of the ethic to their everyday work.
Numerous communication tools are used to promote Responsible Care awareness among
employees. At Scotford, this includes presentations at weekly safety stand down meetings, the site’s
e-newsletter, the internal intranet site etc. All new or transferring employees are also provided
information of Shell Chemicals commitment to the Responsible Care ethic, as part of their onboarding process. With the chemicals facilities at both Scotford and Sarnia being located within large
Shell sites and all both chemical and refining facilities being operated by Shell Manufacturing, the
vast majority of all personnel at both sites have, over time, obtained a general awareness of
Responsible Care.
i) To enhance awareness of Responsible Care, it is suggested that, in communications with all
employees at the Scotford and Sarnia sites, Responsible Care be positioned as the “lens” the
Page 17 of 28
public uses to view a company that enables them to view all CIAC companies the same way.
With Shell Chemicals being a CIAC member, it is Shell’s responsibility is to ensure that all
Responsible Care expectations are embedded into company systems. Note- Displaying
Responsible Care as an umbrella is a useful visual aid.
ii) With global Shell leadership gaining increased awareness of Responsible Care and CIAC having
increased Responsible Care promotional expectations for member companies, SCCL are
encouraged to challenge corporate restrictions which inhibit their ability to include Responsible
Care on commercial documentation business cards and other promotional materials.
3f)
Workplace Health & Safety
The team looked at the company’s processes for continuous improvement in protecting the safety
and health of employees, contractors and visitors.
FINDINGS
Overview:
There is a clear focus evident on continually improving the company’s health and safety
performance, through a belief that all occupational injuries and illnesses are preventable.
There is a documented Health, Safety, Security & Environment Management System program
(HSSE MS) in place, which addresses identification and evaluation of hazards, behavioural
expectations, and operational controls and procedures. There is also a documented program in place
which outlines the requirements for ensuring the health and safety of contractors and visitors.
Significant incidents are managed in accordance to the Group Incident Classification, Investigation
and Reporting Guide. All Shell Chemical incidents are risk ranked in the area of People,
Environment, Asset and Reputation using a qualitative Risk Assessment Matrix (RAM). Actions
required are determined based on the outcome of this risk assessment system.
The health and safety hazard identification process includes job safety analysis, exposure
assessments, health assessments, workplace hazardous materials information, material safety data,
and hazard communications, indoctrination, and training employees, based on their potential for
chemical, physical or biological assessment exposure and their age, the baseline medical
assessment and the health surveillance and screening examinations required.
In addition, to prevent and control health and safety hazards at the job/task level, written operational
controls and task procedures are implemented for activities such as confined space entry, electrical
work, hot work, hydro blasting and pressure washing, lock-out and isolation of energy sources.
New health risks recently discovered by medical sciences and/or as a result of studies conducted by
medical sciences are communicated to employees as appropriate.
On a worldwide “Safety Day” in 2009, global Shell rolled out a “Goal Zero” initiative with the overall
metric including a large suite of metrics. Following an extensive analysis of previous major incidents,
“12 Life Saving Rules”, setting out clear “do’s and don’ts” covering highest potential safety risk
activities and three “Golden Rules” (comply, intervene, respect) were established. Compliance with
the Life Saving Rules is mandatory for both company employees and contractors with serious
consequences (termination of employment) for non-conformance. Management at both
manufacturing sites believe that this new focus has resulted in the improved safety performance
recently experienced.
Page 18 of 28
A unique recent Shell initiative is their “Journey Management Plan” which must be completed by
personnel driving in excess of 4.5 hours in a day. Limitations are placed both daily driving and
combined daily working and driving hours. Other considerations include bad weather,
communications capabilities etc.
Best Practices:
i) The “Goal Zero” initiative with “12 Life Saving” and “3 Golden” Rules.
ii) Tracking and visibly displaying the number of days since the last “Goal Zero” incident.
iii) The “Journey Management Plan” travel safety initiative.
3g)
Site Risk Communications
The team looked at the company’s management system for ongoing communication and dialogue on
the risks of its site operations with potentially affected communities.
FINDINGS
Overview:
The company’s approach is to create trust and demonstrate accessibility to neighbours so they know
that they can request information and that it will be provided. The philosophy is not just doing
“things”, but more about having a relationship with the community that engenders trust and
openness.
Some examples are as follows:
 Annually, the Scotford site provides a Public Information Package that contains information about
the Scotford Emergency Response Plan, public safety actions, and specific information regarding
the characteristics, and health impacts of chemicals that on site, such as ethylene oxide. During
the 2010 fall season, they also provided information on the worst-case scenario, which included
additional information on risks as perceived by their neighbours.
 Information that neighbours can “see, smell or hear” is recorded on a call-in telephone line (i.e.,
NR CAER Update Line) at Scotford. This line is well used by both industry and neighbours in
maintaining an awareness and understanding of industry activity. It is considered by the company
to be a key reason why they receive few complaints; of which there were none in the year prior to
this Re-verification visit.
 Sarnia recently sent out Emergency Response information in a targeted mail campaign to 3500
surrounding homes and businesses. It included a laminated card with Chemical Valley
Emergency Coordination Organization (CVECO) emergency codes, a magnet displaying Shell’s
Community notification number, the number to their Community Relations Representative, their
website address and a letter from the site’s General Manager
3h)
Dialogue Process with Communities
The team looked at how the company’s 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.
FINDINGS
Overview:
At Scotford:
Page 19 of 28





Employees participate in Shell Chemicals sponsored community events such as the Fort Trade
Fair and Josephburg Chicken Supper as a means to put a face(s) to the facility with the benefit of
enhancing transparency and trust.
Neighbours receive quarterly newsletters from Shell Scotford featuring information about their
operations, including upcoming events such as turnarounds.
The site hosts bi-annual community meetings where neighbours have the opportunity to have a
dialogue with the site management team. One of the annual meetings also includes other area
industries. These meetings typically end with a “Question and Answer” session where neighbours
are able to ask management about any issues or concerns that they may have.
The “Life In the Heartland” group, which includes City of Fort Saskatchewan and Strathcona
County representatives, communicates risk information beyond a 5 km radius of the Scotford site.
A “ground truthing” program is in place involving face-to-face visits with approximately 70 site
neighbours each year.
At Sarnia:
 Direct mail is sent prior to planned activity at site. i.e. turnarounds
 The Community Relations Representative and site General Manager participate in the eight
annual meetings of the Bluewater Community Advisory Panel
 The General Manager currently chairs the Community Awareness Emergency Response
organization (CAER), whose mandate includes public notification during an emergency.
 The site hosted, from their perspective, a very successful open house in 2008, which attracted
over 500 neighbours. Bus tours of the facility were provided and neighbours had a chance to
meet with employees
Best Practice:
i) The Scotford site “ground truthing” process through which approximately 70 stakeholders located
within a five km radius of the site are visited every two years.
i) Promote the “Life in the Heartland” group’s existence and role in risk communications to
stakeholders within their targeted service area...
ii) Document the community outreach processes while ensuring that CAER code expectations are
included.
3i)
Social Responsibility
In this area the team was not looking for evidence that the company's performance met certain
expectations, but rather for information on 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. Aspects considered include working with schools,
progressive employee programs, support for charitable work, policies for investments and operations
abroad, workplace diversity, corporate ethics policies, policies for suppliers in social responsibility,
etc.
FINDINGS
Overview:
Both the Scotford and Sarnia facilities have a Social Performance Plan (SPP). The objective of the
plan is to mitigate negative impacts and to determine how to best use their resources and expertise
to provide benefit to the community based on local issues. The plan defines the social environment
and assesses social impacts through stakeholder engagement. The SPP also includes a social
investment strategy and ways to minimize impacts on cultural heritage.
Page 20 of 28
All SCCL sites (Calgary office, Scotford and Sarnia)
The Calgary office, Scotford facility and Sarnia facility are active supporters of United Way. Shell
employees donate millions of dollars to the United Way each year. They also have many progressive
HR related programs:
 Shell’s Community Service Fund is a program that rewards non-profit organizations in which
employees/retirees volunteer. This program is used by employees in Calgary, Sarnia and
Scotford and directly benefits local communities.
 An active Diversity program designed to build respect and inclusiveness into their culture as the
way Shell does business.
 Summer and Co-op Student Hiring Program.
 Community Service Fund - a program that rewards non-profit organizations in which Shell
employees/retirees volunteer. This program is used by employees in Calgary, Sarnia and
Scotford and directly benefits local communities.
Scotford
Some of the positive social impacts Shell Scotford provides beyond jobs, goods and services
purchased and taxes are:
 Provided a $750,000 contribution the Fort Saskatchewan Community Hospital Foundation which
enabled them to purchase a CT scanner. This is the only CT scanner available in hospitals from
St. Albert to Lloydminster,
 Provided a $45,000 contribution to SCRAP, an environmental program that removes rusted
equipment and materials from rural land. Many of these items contain petroleum-based products
that will eventually leak from their respective reservoirs and containers. These contaminants
have the potential to leech into the soil, and in many circumstances could find their way into the
surrounding wetlands, watercourses, lakes and groundwater.
 Provided a $20,000 contribution to the Fort Saskatchewan Public Library's development of a new
reading area and literacy programs
 Provided funding for Skills Canada’s Provincial skills competition. Skills Canada Alberta is a notfor-profit association that promotes skilled trade and technology careers to Alberta’s youth
through innovative programs that take students out of the traditional classroom setting.
 Provided 30+ volunteers at a popular community event that serves as an important fundraiser for
local programs enhancing quality of life in the area. Scotford employees volunteer for this local
event annually.
 Donated a fire truck to the Bruderheim Fire Department in 2009
 Supporting key community initiatives to manage community interests and desires with the
increased industrial growth in the region. Scotford staff participate within the following
organizations to support community initiatives and manage community interests and desires;
Northeast Region Community Awareness & Emergency Response (NRCAER), Volunteer
Residential Property Purchase Program (VRPPP), and Fort Air Partnership (FAP).
 Providing leadership to the Life in the Heartland Association, addressing community concerns and
understanding
Sarnia
 Provided lead $500,000 gift to Lambton College towards Sustainable Technology programs,
which is helping to fund new labs and programs at the college
 $140,000 to Bluewater Health towards new hospital project. Shell’s gift funds a ‘Healing Garden’
found at the entrance of the main foyer of the hospital.
 $20,000 to Oil Heritage Museum in Lambton County to go towards renovation of the building
 $20,000 to Bluewater Trails to support bicycle/walking trail link through Lambton County and
Sarnia
Page 21 of 28
 Shell’s Community Representative chairs “Visions of Harmony” committee made up of First
Nations representatives and Industry. Several youth career fairs and “Careers in Technology”
sessions are facilitated annually through VOH at surrounding First Nations reserves.
 Shell employees participate annually in the United Way Day of Caring, where they spend the day
helping seniors and non-profit organizations with tasks like painting, cleaning, yard work, etc.
 Shell has the second largest United Way workplace campaign in Sarnia-Lambton
Calgary Office
The Calgary office has an ongoing program of active support through volunteerism. Mustard Seed
and Habitat for Humanity have been underway since the previous Re-verification.
 Provided funding for the Bull X Fire Extinguisher simulator system. This funding led to a
partnership with the Calgary Fire Dept (CFD) and will entitle Shell to have 4 employee training
sessions a year with the equipment. The CFD will also use this equipment to help train other
interested parties within the community with the goal to achieve a base knowledge on fire
science, fire extinguisher use and maintenance. Examples of interested parties include group
homes, workers at daycare centres, seniors assisted living centres, personnel at schools,
private/public companies, and recruitment fairs for the CFD. SCCL believes that this CFD
partnership demonstrates a dedication to safety and the safety of its employees, promotes
education and sharing of valuable information, and gives back to the community.
3j)
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’s process for establishing ongoing relationships with elected officials (i.e., MP's, MPP's, city
councillors, etc.) in constituencies where the company has a presence, to acquaint those officials
with the nature of the company’s operations, economic impact, Responsible Care commitment,
activities and public policy concerns, and to understand the elected officials’ interests and concerns.
Also reviewed were the company’s engagement in CIAC activities aimed at assisting in the
development of sound public policy (e.g., Parliamentary Day, policy discussions, lobbying, etc.).
FINDINGS
Overview:
Shell Chemicals engagement with elected officials occurs on two fronts. At the manufacturing
facilities, management engages local elected officials as part of ongoing community outreach
activities such as open houses or public information sessions. Senior management and SCCL
Officers engage Provincial and/or Federal elected officials a part of CIAC association activities
including Parliamentary Days, discussions on issues of the day or when drafting emerging legislation.
3k)
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.
FINDINGS
Overview:
Shell Chemicals employs a carrier selection process to ensure selected carriers are competent in a
number of areas such as Health, Safety, Security and Environment including other criteria according
to the Canadian Motor Carrier Evaluation Guide. All product shipments are tracked using a program
called Roadrunner to determine locations. Trailer and railcar loading valves and hatches are sealed
prior to and checked upon unloading to ensure tampering has not occurred. All loading and
Page 22 of 28
unloading is typically completed within fenced areas were access is controlled. If there is suspicion
of tampering customers and carriers are required to report it to CHEMTREC who in turn contacts
SCCL to initiate an investigation.
In January 2010, SCCL was advised by US Department of Homeland security that its responses to a
re-validation report showed that SCCL is meeting all of the minimum-security criteria as required for
participation in the C-TPAT Program. Accordingly, SCCL has a three (3) year certification as a CTPAT partner with US Customs.
3l)
Carrier Selection
The team looked at the company’s 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.
FINDINGS
Overview:
For Marine Operations, Shell Chemicals Global Marine division follows a nomination procedure for
both deep sea and short sea applications. Products currently shipped by marine include IsoPropyl
Alcohol (IPA) from Sarnia via the St. Lawrence Seaway.
The company has a well-defined motor carrier selection and qualification process, which includes
review and monitoring of environment, health and safety performance prior to and during the
execution of carrier contracts. Every two years Shell Chemicals through its service provider SCCL
nominates carriers to be audited by CIAC’s third party contract assessor. The results are reviewed
focusing on the areas of improvement identified.. SCCL works to ensure the corrective action has
been taken in a timely manner. The Shell Chemicals carrier qualification process recognizes
Responsible Care partners in addition to HSSE performance matrices such as accident rates and
Workers Compensation Board (WCB) rates.
A quarterly continuous improvement meeting between Shell Chemicals Logistics Management and
contract carriers allows dialogue on subjects such as HSSE performance, and Shell Chemicals driver
safety programs.
3m)
TransCAER Outreach
TransCAER is the CIAC program for Transportation Community Awareness and Emergency
Response. It involves the company’s 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.
FINDINGS
Overview:
The Shell Chemicals Terminal Contract Manager is Co-chairperson of the Prairie Regional
TransCAER committee after being Chairperson for the three previous years.
The company is represented in community meetings, and continues to be actively involved in
regional TransCAER events. Since the last verification, the company has participated in the following
events:
Page 23 of 28
o
o
o
2008: Balzac, Olds and Banff
2009: Rocky Mountain House, Alberta and Saskatoon, Saskatchewan
2010: Saskatoon, Saskatchewan
The outreach events consisted of a number of companies providing information to the public about
the products they transport, and all the programs they have in place to ensure safe transportation of
goods. These events included a display of emergency response capabilities, and a static display of
the CIAC demonstration rail tank car.
4.
CONCLUSION
As a result of the Calgary Headquarters, Scotford and Sarnia site visits, documentation reviews,
many interviews with company personnel, and a meetings with a cross section of Scotford site
neighbours, the re-verification team is satisfied that the company’s decision-making and actions are
strongly underpinned by the Responsible Care ethic, and that the overall management system is selfhealing (i.e., based on a process of continual performance improvement, and identification and timely
correction of deficiencies). This was also demonstrated by the clear commitment of company
personnel to do the right thing and do it well.
5.
COMPANY COMMENTS
On behalf of Shell Chemicals Americas Inc. (SCAI) and Shell Chemicals Canada Limited (SCCL) I
have reviewed this verification report. The observations and conclusions contained in the report have
been discussed with the verification team.
Shell Chemicals Canada Ltd. and Shell Chemicals Americas Inc. wishes to express its appreciation
for the time, energy and commitment of the Responsible Care® Re-verification Team and for their
review of our management systems and our performance in support of the RC ethic.
We welcome the observations that have been made as “Findings Requiring Action” and
"Opportunities for Improvements". We also appreciate the many positive comments the Reverification Team shared with Shell Chemicals personnel while visiting each of the facilities and
highlighted in the report as “Best Practices/Extra Miles”. We are grateful for the recognition provided
to many of our employees. This positive approach will help reinforce our commitment to the
Responsible Care® Ethic and Principles.
Shell Chemicals Americas Inc and Shell Chemicals Canada Limited will communicate the results of
the verification exercise with its CIAC peers at their next meeting, and will discuss the verification
results with our stakeholders, including those representing communities near our operating sites.
We will give consideration to the Improvement Opportunities identified by verification team and will
assist the CIAC in communicating and sharing the identified Successful Practices to other CIAC
members. Plans will be developed and implemented to respond to the Findings Requiring Action
identified by the verification team. Our progress in implementing those plans will be discussed when
preparing our Annual Statement of Re-Commitment to Responsible Care, and communicated to the
verification team at the time of our next verification.
Scott Desilets
President
Shell Chemicals Canada Limited
April 18, 2011
Page 24 of 28
APPENDIX 1
COMPANY DESCRIPTION AND CHANGES
Shell Chemicals Canada Ltd. (SCCL) has been in existence since Shell acquired the minority
shareholding in the Chemicals segment of Shell Canada Ltd at the end of 1996. From 1997 to early
2004, SCCL operated as the corporate entity for Shell’s chemicals business in Canada. With the
addition of regional customer services and finance responsibilities in Calgary and the requirement to
provide these services, including exports, to Canadian business and Shell’s US chemicals company.
Shell Chemical LP (SCLP), a new sales and marketing company, Shell Chemicals Americas Inc.
(SCAI), was established. In general terms, SCAI purchases product from SCLP and SCCL for resale
to customers in Canada and to export destinations. Shell Chemicals exists in Canada as two
companies. For the purposes of Shell Chemicals governance in Canada, the President and LSCR
(Local Senior Chemicals Representative) have responsibilities to ensure all Shell chemicals
businesses i.e. both SCCL and SCAI, are meeting legal and externally driven requirements in
Canada (i.e. ensure regulatory compliance, Responsible Care and other external commitments,
business ethics and principles, corporate financial reporting and tax requirements etc. are being
discharged appropriately).
With their Headquarters in Calgary, SCCL produces styrene, ethylene glycol and isopropyl alcohol at
manufacturing sites in Scotford (near Fort Saskatchewan), Alberta and Corunna (near Sarnia)
Ontario. In August 2008, SCCL repurchased assets located in Corunna which had been sold several
years previously to Basell Canada. These included a polypropylene plant, which was subsequently
shut down, along with an isopropyl alcohol (IPA) plant, and a feed process unit and associated
utilities that continue operating. Both chemical plants are located adjacent to SCCL’s affiliate’s (Shell
Canada Products) oil refineries and, at both locations, the chemical plant and oil refinery are
operated by a common team.
SCCL sells its products to Shell Chemicals Americas Inc. (SCAI). SCAI is the marketing company for
(i) all Canadian domestic sales of chemical products, (ii) all exports of Canadian made chemical
products, and (iii) exports of US made chemical products where a Shell entity arranges
transportation.
Since the previous Re-verification in 2007, there have been significant personnel and role changes
related to chemicals operations at SCCL’s Corporate Headquarters in Calgary as well as at the
Scotford and Sarnia manufacturing sites. These changes have had a significant impact on how
Responsible Care is implemented within SCCL as discussed in more detail in the body of this report.
Page 25 of 28
APPENDIX 2
TEAM AND CONTACTS
1.
The Verification Team
The verification team consisted of the following:
Name
Affiliation
Representing
Alec Robertson
Consultant
Industry (team leader)*
Gerry Whitcombe
Consultant
Industry*
Keith Purves
General Public
Public at Large*
Mary Chartrand
Area Resident
Fort Saskatchewan Community
Heather Haines
Area Resident
Sarnia Community
Team members assigned by CIAC are shown by an asterisk (*).
2.
Persons contacted at the company
Name
Position
Scott Desilets
President/Regional Customer Centre Manager, CIAC Executive Contact- Calgary
Elizabeth Williams
Chemicals Product Stewardship Manager-Calgary
Dean Dobrescu
Contract Manager – Road-Calgary
Susan Steele
Contract Manager – Terminals – Calgary
James Deleon
Contract Manager – Rail –Houston, via teleconference
Mike Drumm
HSSE Country Specialist &-ER Lead, Overall Responsible Care Coordinator Calgary
Doug Crighton
HSSE MS Coordinator – Scotford
Paul Gabbard
General Manager -Shell Manufacturing, Scotford
Jeff Bulger
HSSE Manager- Shell Manufacturing, Scotford
David Onderwater
Technical Manager - Shell Manufacturing, Scotford
Peter Reuderink
Production Manager - Shell Manufacturing, Scotford
Jeff Brock
Safety Manager - Shell Manufacturing, Scotford
Murray Karain
Process Safety Mgr.- Shell Manufacturing, Scotford
Ludmila Shustova
HSSE Analyst - Shell Manufacturing, Scotford
Amber Hayton
Incidents Focal - Shell Manufacturing, Scotford
Randy Provencal
Community Relations Manager – Shell Downstream
Jennifer Downs
Community Relations Representative– Scotford Site
Margit Phillips
Community Relations Manager– Scotford Site
Yolanta Leszczynski Regulatory Coordinator – Scotford
Pascal Bellerose
Process Manager - Shell Manufacturing, Scotford
Kelly Margetts
General Manager - Shell Manufacturing, Sarnia
Steve Lacey
Production Unit Mgr. - Shell Manufacturing, Sarnia
Gord Walking
HSSE/Env. Advisor - Shell Manufacturing, Sarnia
Kristina Zimmer
Community Liaison Officer – Sarnia
Lee Simpson
Production Specialist - Shell Manufacturing, Sarnia
3.
Process for obtaining information
The process followed the current CIAC protocol for Responsible Care Re-verification, and consisted
of a series of interviews with management, support staff and hands on employees, document
reviews, and site inspections.
Visits were made to the company’s corporate Headquarters in Calgary and manufacturing facilities in
Scotford, Alberta and Sarnia, Ontario.
Page 26 of 28
A meeting was also held with the community representatives in the Scotford area to obtain the
perspective of local residents.
Page 27 of 28
APPENDIX 3
FACT-FINDING QUESTIONS RE NEW RESPONSIBLE CARE ETHIC & PRINCIPLES
FOR SUSTAINABILITY
“Describe any new things you, at the site and/or corporate level, have considered, are doing or
have started to do with respect to these concepts:
Greenhouse Gas Initiatives
There is a growing need in the Shell businesses for technically sound, transparent and consistent
carbon intensity analysis of Shell's products and processes. A Greenhouse Gases Intensity Analysis
Team (GIAT) was created in 2008 to improve the carbon-foot printing (well to wheel or WTW)
analysis within Shell. All case studies for products or components and the technical support to
advocacy activities are managed by the GIAT.
In line with the larger Shell activities, the Shell Chemicals business has developed its strategy to
address the increasing impact of a carbon constrained future and its emerging regulations on their
products and business. In order to understand the carbon intensity of Shell chemical products (in
tons of CO2e/ton product), a detailed analysis has been conducted for the main Shell chemical
products. These footprints show the relative contributions from the different process steps from
feedstock production up to and including the chemical production processes.
In industry or the public domain, no single agreed way to calculate footprints for chemical products or
consumer products exists, yet. A methodology was developed in order to calculate these carbon
footprints and that has been shared within the chemical industry. The actual values determined are
also provided to customers upon request.
International Council of Chemical Associations (ICCA) Support
Two senior managers in Shell Chemicals sit as Co-Chairs on the ICCA Advocacy Task Force. The
primary purpose of the ICCA CP&H Advocacy Task Group is to position the industry as a positive
contributor to the safe and environmentally sound use of chemicals with key governments and
intergovernmental organizations (e.g. UNEP). In the near-term, the primary focus of the ICCA CP&H
Advocacy Task Group will be to position the status, trajectory and ultimate contribution of the
chemical industry to achieving the WSSD goal. Longer-term, the Advocacy Task Group will need to
evaluate the international chemical policy landscape, prioritize initiatives, and develop/implement
advocacy strategies/plans. As part of this, Shell Chemicals has contributed information on the safe
management of chemicals and individuals to assist NGOs and IGOs in understanding risk
assessment methodologies.
TDI Product Stewardship Initiative for polyol customers
o Shell chemicals companies extend their engagement on TDI Product Stewardship to customers
that only buy polyols from Shell (i.e. Shell is not a manufacturer of TDI which is the hazardous
ingredient in making foam from Shell polyols). Generally, foam manufacturers are not
sophisticated users of chemicals.
o Shell chemicals companies play a role in raising awareness and promoting improvement in the
proper use and handling of TDI at their customers' factories and ultimately across the flexible
foam PU industry
o This initiative represents a significantly higher level of engagement on TDI Product Stewardship
across the polyol customer base
Page 28 of 28
CHEMISTRY INDUSTRY ASSOCIATION OF CANADA
Suite 805, 350 Sparks Street
Ottawa (ON) K1R 7S8
T: 613 237-6215 F: 613 237-4061
www.canadianchemistry.ca

responsible care - Chemistry Industry Association of Canada

Transcription

Documents pareils

2013-14 MT Value shell concept

PRESENTATION TITLE: FUTURA MEDIUM 24PT

SHELL - Platform

responsible care - Chemistry Industry Association of Canada

2.5 plaquette UIC

1 FAST RETAILING Greenpeace Detox Solution Commitment In line

Video Machine A Sous Avec Bonus Casino Jeux Paris Isere

- Aquatic Living Resources