2.1 This procedure applies to all ACC member and Responsible Care Partner Companies unless otherwise noted.

Transcription

1 1.0 PURPOSE 1.1 To ensure that that the s (ACC) Responsible Care Third- Party Audit requirement sustains public confidence and acceptance by defining its requisites for ACC members and Responsible Care Partners. 2.0 SCOPE 2.1 This procedure applies to all ACC member and Responsible Care Partner Companies unless otherwise noted Responsible Care Partner Companies in the rail, marine and bulk liquid storage sectors have the option of using sector-specific certification options described in RCxxx. (to be developed) ACC Affiliate and Associate members are not subject to this procedure. 2.2 All businesses, operations, including corporate and/or divisional headquarters and facilities of an ACC member or Responsible Care Partner company that are considered to be in its calculation for ACC membership or Responsible Care Partnership status are subject to this procedure. 2.3 This procedure does not apply to an ACC member s and Responsible Care Partner s joint ventures or similar entities where the member or Responsible Care Partner company does not exercise controlling interest. 2.4 Any clarification necessary on which facilities this procedure applies, shall be defined by ACC. 3.0 TERMS AND DEFINITIONS 3.1 (ACC) the primary trade association representing the business of chemistry in the United States. It is the sponsor of Responsible Care in the US ( October

2 3.2 ACC Audit Cycle Three-year intervals established by ACC during which members and Responsible Care Partners must complete their Responsible Care Third-Party Audit Requirement. 3.3 Responsible Care Third-Party Audit Requirement Successful completion of RCMS or RC14001 audits at the ACC member s/responsible Care Partner s headquarters and a sample of facilities which is based on ACC s membership/partnership calculations. Members/Responsible Care Partners must successfully complete the required audits by demonstrating conformity to the requirements found in the RCMS Technical Specification, RC14001 Technical Specification or a combination of the two options within each ACC Audit Cycle (See Section ). ACC member and Responsible Care Partners fulfill this requirement as an obligation of membership/partnership. 3.4 Audit Service Provider (ASP) The third-party auditing company that is employed to conduct RCMS/RC14001 audits. If certification is to the RC14001 Technical Specification then the ASP may also be referred to as a certification body (CB). 3.5 Audit Sample Group A sub-group of facilities of a larger group of facilities that have been selected for RCMS/RC14001 audits to meet the Responsible Care Third-Party Audit Requirement (See Section 4.3). ACC companies are required to successfully complete audits at their HQ plus a sample of their facilities to satisfy the Responsible Care Third- Party Audit Requirement. 3.6 Facility for purposes of this procedure, defined as a location falling under an ACC member s/responsible Care Partner s dues calculations at which commercial chemicals are manufactured, handled, transported, stored and where employees or others working on behalf of the ACC member/responsible Care Partner are present. 3.7 Headquarters for purposes of this procedure, the administrative functions by which the Responsible Care/EHSS activities are managed and directed for the organization being audited/certified. A Headquarters may be centralized in a stand-alone location or be a decentralized arrangement with Responsible Care/EHSS activities managed among individuals and teams at different locations. Note: In some cases an ACC member/responsible Care Partner may only have a Headquarters location with administrative offices and no associated facilities. 3.8 Responsible Care a global environmental, health, safety and security performance initiative which was established in Canada in 1985 and adopted by the ACC in Responsible Care is an obligation of membership for ACC members and Responsible Care Partners. The initiative s goals are continuous improvement and responsiveness to stakeholders concerns about the chemical industry s products and operations. 3.9 Responsible Care management system(s) This term with management system(s) in lower case refers to a comprehensive environment, health, safety and security management system(s) whose requirements are defined in the Responsible Care Management System (RCMS ) or RC14001 Technical Specifications. October

3 3.10 RCMS An option for certification under the ACC s Responsible Care initiative. The requirements for RCMS can be found in ACC s document RC101 (current version) RCMS is intended for use by ACC members and Responsible Care Partners within their US and Canadian operations RC14001 An option for certification under the ACC s Responsible Care initiative. The requirements for RC14001 can be found in ACC s document RC151 (current version). RC14001 certification is available to any organization regardless of sector, affiliation or geographic location. (See also RC503) 3.12 Small company ACC member company/responsible Care Partner company reporting <1 million employee exposure hours under ACC s Occupational Injury and Illness Report (OIIR) metric (per OSHA 300 requirements and OSHA definition of small business = < 500 employees) Stage 1 Audit audit to determine if an organization is ready for a certification/conformance audit (Stage 2). For RCMS, the ASP will confirm that the Technical Specification s key requirements are being met; it will confirm legal compliance; implementation status; confirm risk/complexity of facility; and the scope of certification. The output of this audit will be a report identifying any potential nonconformities that the organization will have to correct before Stage 2 audit. ISO requirements for Stage 1 audit are applicable to RC Note: Potential non-conformities may also be identified by other terms provided the ASP is consistent in their use Stage 2 Audit an audit to evaluate the implementation and effectiveness of the organization s management system(s). During this audit, the ASP will determine the degree of conformance with the Technical Specification s requirements, and report any nonconformity that the organization will have to correct before certification can be granted. ISO requirements for Stage 2 audit are applicable to RC RESPONSIBILITIES 4.1 General Fulfillment of ACC s Responsible Care Third-Party Audit Requirement is a mandatory element of the ACC s Responsible Care initiative. All ACC members and Responsible Care Partners shall obtain certification to RC14001 or RCMS (Option 1) or demonstrate conformity to RCMS (Option 2) as required in this procedure to maintain their standing in the ACC s Responsible Care program. Table 1 below provides a comparison of RCMS Option 1 and RCMS Option 2. October

4 Table 1 RCMS Option 1 RCMS Option 2 Scope Audits Certification of Management System Certification audit at HQ and/or facilities Documents conformance to the management system Conformance audit at HQ and/or facilities Annual Surveillance Audit(s) HQ and/or facilities None Company-wide RCMS certification Available (may require larger sample size than identified below in Section 4.3.3, Table 2; see also 4.1.4) Not available Type of ASP Acknowledgement Certificate Statement of Conformity ACC Requirements Both Option 1 and Option 2 fulfill Responsible Care Third-Party audit requirement Note: See Appendix 3 for decision tree chart ACC members and Responsible Care Partners can find information on their Responsible Care Third-Party Audit Requirement and Code implementation schedules in their company s Responsible Care Coordinator welcome letter. Note: ACC members/responsible Care Partners can assist in audit planning by sharing welcome letter information with the ASP when planning for the audit If clarification is needed on the ACC member s/responsible Care Partner s Responsible Care Third Party Audit Requirement schedule, it shall consult ACC s Responsible Care & Value Chain Outreach Department. (see Appendix 2 for contact information) The ACC member or Responsible Care Partner shall be responsible for demonstrating conformity to the requirements found in the RCMS Technical Specification or RC14001 Technical Specification through (a) third-party audit(s) RC14001 audits are conducted consistent with ISO initial certification. RC14001 also requires periodic surveillance audits to maintain certification and recertification For RCMS audits (Option 1 or Option 2), determination of whether to conduct both Stage 1 and 2 audits or to combine them in a single audit October

5 based on a company s readiness shall be made in consultation with the ASP. Note: While not required under the RCMS option, Stage 1 audits are recommended for companies conducting their initial RCMS audits at their headquarters and/or facilities or if a company changes ASPs Under RCMS, companies HQ and/or facilities may opt for periodic surveillance audits (Option 1) to maintain certification and obtain a RCMS Certificate (as opposed to a Statement of Conformity RCMS Option 2). If surveillance audits are elected, the company and ASP shall determine the frequency and scope of these audits. Note: For RCMS purposes, ASPs and clients may find ISO and IAF requirements helpful in establishing surveillance schedules Companies have the option to choose RCMS for some facilities and RC14001 for others. In all cases, conformity to the requirements of the Technical Specification being audited at the location is required. In situations where a company opts to mix RCMS with RC14001 audits across its organization, Certificates or Statements of Conformity shall be discrete for each covered location(s). When RC14001 is selected for (a) location(s), relevant ISO and accreditation requirements must be adhered to including relationships and/or interdependency with other facilities. Note: ACC Members/Responsible Care Partners are reminded that other ACC Responsible Care program elements (e.g., performance reporting status, Code implementation, etc.,) are considered auditable under both RCMS/RC Companies may elect to obtain RC14001 or RCMS (Option 1) which covers multiple locations under a single certificate Under the RC14001 option, the process shall conform to International Accreditation Forum s Mandatory Document 1 (current version) and other relevant IAF documents. Note: IAF MD 1 may require a larger sample size than the Audit Sample Group determined by the ACC formula in Section 4.3.3, Table 2.) Under the RCMS option (RCMS Option 1 only), the process shall conform to International Accreditation Forum s Mandatory Document 1 (current version) and other relevant IAF documents. October

6 Note: IAF MD 1 may require a larger sample size than the Audit Sample Group determined by the ACC formula in Section 4.3.3, Table 2.) 4.2 Auditing Firms Certification of multiple locations under a single certificate shall be to either RC14001 covering all the locations or RCMS (Option 1) covering all the locations. There shall be no mixing of RC14001 and RCMS (Option 1) audits under a single certificate RCMS/RC14001 audits shall be conducted by auditing firms which have been approved/accredited for these services by the ANSI-ASQ National Accreditation Board (ANAB) ASP requirements for RCMS providers can be found in RC502 (current version) and for RC14001 providers in RC503 (current version) If clarification is needed regarding the ASP s credentials, see Appendix Any disputes over an ASP s credentials shall be resolved prior to the start of an audit. 4.3 Determining the Number of Required Audits The Responsible Care Third-Party Audit Requirement includes audits at the ACC Member s/responsible Care Partner s headquarters and a sample group of facilities as defined in Table 2 below The ACC Audit Cycle occurs on a three-year timeline as defined by ACC. At least once in every ACC Audit Cycle the headquarters shall be audited to ensure continuity of the management system between the headquarters (HQ) and facility operations Audits shall be initiated on a timetable consistent with the ACC Audit Cycle schedule presented below. The schedule shall be renewed every three years. Each Audit Sample Group shall consist of the Headquarters (HQ) and a selection of facilities. For purposes of calculating the number of facilities required using the 33% requirement in Table 2 below, fractions of facilities greater than or equal to a fraction of 0.50 shall be rounded up to the next whole number and.49 and less shall be rounded off down to the previous whole number. October

7 Table 2 Company Size 1-25 facilities Requirements 33% of facilities(up to a maximum of 4) + HQ Per designated ACC Audit Cycle Complete all required audits facilities 6 facilities+ HQ 41+ facilities 8 facilities+ HQ Complete all required audits Complete all required audits Note: ACC Audit Cycle at the time of the publication of this document extends from January 1, 2017 December 31, The next ACC Audit Cycle begins on January 1, 2020, etc Unless the number of the ACC Member s/responsible Care Partner s eligible facilities makes this requirement mathematically impossible, at least 2/3 of the Audit Sample Group shall be facilities that have not undergone a certification audit in the previous cycle The details of the selection methodology used to determine the Audit Sample Group shall be developed and agreed to by the ACC Member/Responsible Care Partner and the selected ASP. In the event an ACC Member/Responsible Care Partner uses the services of two or more ASPs (different ASPs at different locations), it shall be the responsibility of the Member/Partner to coordinate planning and alignment between itself and its ASPs Headquarters selection may be made based on geographic location, business affiliations with facilities, and other factors. ACC members/responsible Care Partners and their ASPs are encouraged to manage audit scope and travel schedules to promote efficiency in auditing headquarters processes that are performed at different locations. If a company s HQ is located outside the United States, a business unit within the US may be designated. Note: Clear definition and agreement on the scope and interfaces of the headquarters and facility management systems is an important consideration in planning these audits When conducting a headquarters audit for RC14001, the company and its ASP shall ensure conformance with all relevant ISO procedural requirements. October

8 4.3.7 Selection of the appropriate Audit Sample Group may be made considering measures relating to relevant risks, as well as other factors such as randomness, facility size, stakeholder perceptions, geographic location or complexity Both the ASP and the ACC Member/ Responsible Care Partner shall ensure that the selection of facilities for the Audit Sample Group is not directed only towards pre-determined or flagship locations When conducting facility audits for RC14001, the company and its certification body shall ensure conformance with all relevant ISO procedural requirements Facilities which are new to the ACC Member/Responsible Care Partner are excluded for three years from those facilities that are considered when determining the Audit Sample Group. Note 1: This includes newly-acquired facilities and/or newly-built facilities. Note 2: ACC members/partners seeking certification of multiple locations under a single certificate (See Section 4.1.4) should consult with their ASP on determining how to bring new facilities under the certificate in the most efficient and effective manner Member companies meeting ACC s definition of small are allowed to combine their HQ audit with an adjacent facility into a single audit. This single audit shall meet the company s HQ audit requirement and one facility audit requirement. (See Appendix 1) The ACC member/ Responsible Care Partner shall maintain a record of the methodology and justification used to select its Audit Sample Group and subsequent certification of each facility in accordance with its internal document retention policy ACC reserves the right to establish agreements with other Responsible Care organizations regarding RCMS/RC14001 certification which may affect elements of this process such as Audit Sample Group makeup and facility location. Agreements of this type will be developed under existing ACC processes under direction of appropriate ACC program committee(s) and addressed through separate Memorandums of Understanding and communicated to all relevant parties. 4.4 Public Participation ACC Members/ Responsible Care Partners may choose to include public participants in their audit processes for both the Headquarters and facility October

9 4.5 Security-related Items audits. If public participants are to be included on an audit, ACC Member/ Responsible Care Partner and ASP shall determine how this part of the process will be implemented Security is a component of both the RCMS and RC14001 Technical Specifications and subject to review. ACC members/responsible Care Partners shall ensure that arrangements are made prior to the start of an RCMS/RC14001 audit regarding ASP access to security-related materials. ASPs and their clients shall work together to ensure that security-related information is protected and legal restrictions are followed while not compromising the integrity of the RCMS/RC14001 audit. 4.6 Reporting Status Note: The use of auditors who are Chemical-terrorism Vulnerability Information (CVI) Authorized Users may alleviate concerns regarding access to security-related information The ACC Member/Responsible Care Partner shall report its RCMS/RC14001 status to ACC as part of its Responsible Care performance reporting obligation ACC members/responsible Care Partners are encouraged to publicize their RCMS/RC14001 status to their stakeholders. 5.0 RECORDS GENERATED 5.1 Summary of selection methodology and justification, and Audit Sample Group (ACC member/responsible Care Partner) 5.2 Audit Reports for each facility and headquarters (Audit Service Provider, ACC member/ Responsible Care Partner) 5.3 Certificate (RC14001 or RCMS Option 1) or RCMS Statement of Conformity (RCMS Option 2) 6.0 REFERENCE DOCUMENTS RC101 RCMS Technical Specification (current version) RC151 RC14001 Technical Specification (current version) RC502 RCMS ASP requirements (current version) RC503 RC14001 Requirements for Accreditation Bodies, Certification Bodies, Organizations and (current version) RC205 Responsible Care Certification Auditor Qualification and Training Requirements (current version) RCxxx Sector-specific Certification Options (current version) (to be developed) October

10 ISO Conformity Assessment Requirements for Bodies Providing Auditing and Certification of Management Systems (current version) 7.0 REFERENCE LINKS ACC Website: IAF Mandatory Directive 1: October

11 APPENDIX 1 - Special Case: Small Company Option In an effort to define specific boundaries of flexibility in the ACC s Responsible Care Third-Party Audit Requirement while maintaining its integrity and purpose, options for companies that fall into very specific and limited special case categories are detailed below. The two special case categories, qualification criteria, and certification options are summarized below. Special case options are offered to small companies, as defined below under existing ACC definitions, and would result in the combined headquarters and facility audits for all qualified, self-nominated members/partners. Qualifying criteria: Small Company Scenario A a. ACC Member or Responsible Care Partner must qualify as a small company (See Item 3.12) The Company s employee OIIR data (which is reported annually to ACC and includes annual exposure hour totals) will be used to determine whether it is considered small and in scope for this special case. b. The company has a facility and headquarters (HQ) that are adjacent geographically and both of which are subject to the Responsible Care Third-Party Audit Requirement. Requirements: a. The Company must complete the combined HQ-facility audit by the end of the current ACC Audit Cycle. b. Companies that conduct combined audits and have additional required facility audits in their Audit Sample Group must complete other required facility audits by the end of the current ACC Audit Cycle. Qualifying criteria: Small Company Scenario B a. ACC Member or Responsible Care Partner must qualify as a small company. (See Item 3.12). The company s employee OIIR data (which is reported annually to ACC and includes annual exposure hour totals) will be used to determine whether it is considered small and in scope for this special case. b. The Company has a "minimal" level of Responsible Care activities at its HQ. The company may elect to conduct a combined HQ-facility audit by bringing HQ staff and appropriate documents and records to a facility for combined audit. In this situation, both the HQ and facility functions are subject to the audit. For companies opting for a RC14001 audit, it may still be necessary to conduct separate audits at the HQ and facility in order to conform to relevant ISO requirements. The company shall consult with its ASP regarding conduct of RC14001 audits under this scenario. October

12 Certification Requirements: a. The Company must complete the combined HQ-facility audit by the end of the current ACC Audit Cycle. b. Companies that conduct combined audits and have additional required facility audits in their audit sample must complete other required facility audits by the end of the current ACC Audit Cycle. If a company or its ASP requires clarification on its status as a small company, please refer to Appendix 2 ACC Contact Information for questions. October

13 APPENDIX 2 ACC Contact information For information regarding the ACC s Responsible Care Third-Party Audit Requirement, please contact: Daniel Roczniak Senior Director, Responsible Care and Value Chain Outreach 700 Second Street NE Washington, DC Dan_roczniak@americanchemistry.com Inquiries may also be sent to ACC at: Responsible_Care@americanchemistry.com RC14001 To purchase a copy of the RC14001 Technical Specification ( ) October

14 Appendix 3 - RCMS/RC14001 Decision Tree (for reference only) October

15 DOCUMENT CONTROL Name and Title Signature Date Written By: Owner: Approved By: ACC Procedures Task Force ACC Responsible Care Committee ACC Responsible Care Committee Andy Piper, Chair Maria Krysa, Chair Maria Krysa, Chair 9/15/ /30/201 10/30/201 REVISION LOG REVISION NO: REASON FOR CHANGE(S): DATE: 01 This document along with new RC502 and RC503 replace previous RC201 and RC204 documents. 10/30/2017 October