According to Danny Forest, director of data analytics for the American Chemical Council (ACC), there is a specific slate of Environmental, Health and Safety (EHS) requirements that must be met in order for a site to become what industry has dubbed a Responsible Care facility - the 38-year voluntary initiative to drive continual EHS improvements.
First, Forest said, the site must become a member of ACC and then must follow ACC's process safety codes.
The codes were originally issued in 2012 in response to high-profile safety incidents and to increase regulatory attention.
"The unfortunate part of our jobs is usually safety action that comes out of consequence," Forest said at the EHS Seminar & Industry Trade Show, held recently in Galveston, Texas.
ACC's process safety codes were implemented to apply learnings from process safety management (PSM) covered facilities and apply those lessons to non-PSM facilities.
In 2021, ACC reviewed its Responsible Care protocol.
"One of the major takeaways from the strategic review was, we would take a look into all of our codes and update them," Forest said, noting that ACC's security code hadn't been updated since September 11, 2001, when it was first implemented.
Process safety operators and managers from across the industry volunteered on the committee to help update the codes.
Forest said countless hours were spent developing both best practices, and how to present them to industry.
To determine what the changes would entail, ACC focused on leadership, Forest said, "making the delineation between corporate leadership and facility leadership. We tried to change the language - to be more action-oriented and added examples of what 'good' looks like."
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Danny Forest, director of data analytics for the American Chemical Council
Forest said they weren't attempting to make the code a "one-size-fits-all" resource but that there are certain lessons to be learned and applied to individual sites.
Forest said ACC is also developing an implementation guide "that will have more of those nuances like, 'This site did this, and it worked really well,' so you might be able to take some lessons learned from them, and apply it to yourselves."
Stronger language, defined expectations
Explaining other revisions included in ACC's 2021 update to the Responsible Care protocol, Forest said one noticeable change was to firm up the code's language.
"We use the phrase 'will do' because if you're practicing Responsible Care, you're obligated to use the process safety code," he said.
Another significant change ACC members would notice "right up front," Forest said, was the consolidation of two management practices.
The new Management Practice #1 merged former Management Practice #1, "Leadership and Culture" with Management Practice #2, "Accountability." The merger established clearer delineation between senior leadership and facility leadership.
"It also expounded on the difference between leadership and culture," Forest said. "We were able to do that in such a way that it did not limit the quality of the code." Management Practice #2 changed the term "Accountability" to "Knowledge Expertise and Training."
"It expands on the different stakeholders at an organization, and also acknowledges the need for competency requirements for contractors," Forest said.
Management Practice #3, formerly known as "Knowledge Expertise and Training," became "Identification and Prioritization of Process Safety Risks."
"It emphasizes the importance of understanding risks and underscores the need to identify, rank and communicate risks," Forest said.
Management Practice #4, earlier known as "Understanding and Prioritization of Process Safety Risks" was retitled "Comprehensive Process Safety Management Systems."
"It expands on the components of a comprehensive management system. It also adds operational objectives for emergency response and contractor safety," Forest said.
There's not much difference in the updates of management Practices #5 and #6, Forest said.
"The language is much more actionable, and titles changed for both practices," he explained.
Forest said that ACC sought to make the code clearer in terms of process safety expectations.
"We hope this provides not only a document that is easier to read, but also that has more value that you can bring to your site," he concluded.
For more details about changes and updates to the codes, ACC members are encouraged to visit AmericanChemistry.com.
