Each member company shall have an active program designed to continuously improve safety and reduce incidents. This Code does not impose upon member companies any obligation to guarantee compliance by third parties, i.e., parties over whom the member companies have no control. This program shall include: CODE I: Senior Management Commitment and Risk Management 1.A. 1.B. Senior Management commitment through review of the Responsible Distribution Code, Guiding Principles, policies, and procedures and action taken to ensure its continuing suitability, adequacy and effectiveness. Senior Management commitment to ongoing improvements in chemical distribution, education, environment, health, safety, and security through communication to Stakeholders, the implementation of policies and procedures, the allocation of resources, and personnel accountabilities. 1.C. Identification and evaluation of environment, health, safety, and security (EHS&S) risks and the prioritization of identified risks. 1.D. Regular review with suppliers of the hazards of materials, revising policies and procedures as necessary. 1.E. 1.F. Process, policy and procedure changes involving EHS&S issues are made and communicated. Senior Management, Responsible Distribution Code Coordinator, and other key personnel trained on all aspects of Responsible Distribution. CODE II: Compliance Review and Training 2.A. 2.B. 2.C. 2.D. 2.E. A process for monitoring environmental, health, safety, and security (EHS&S) regulations and industry practices for the application to chemical distribution activities. A process for implementing applicable regulations and industry practices that apply to chemical distribution activities. Training for all in the implementation of applicable EHS&S regulations, as well as member company s specific requirements. A process for reviewing safety and loss prevention policies, procedures, and/or program. A process for reviewing employee compliance with applicable regulations and member company s specific requirements, as well as outside contractor and re-seller compliance.
CODE III: Carrier Selection and Private Fleet 3.A. 3.B. A process for selecting carriers to transport chemicals that includes carrier safety and fitness, security, and regulatory compliance, including ongoing performance review. A process for private fleet in the transport of chemicals that includes safety and fitness, security, and regulatory compliance, including ongoing performance review. CODE IV: Handling and Storage 4.A. 4.B. Selection, facility design, construction, maintenance, inspection, and operating procedures promote facility safety, security, and fitness, consistent with recognized codes, regulations and company policies. A process for selecting contracted sites and facilities for chemical storage and handling that emphasizes environmental protection, safety, security, and fitness including regular/periodic reviews of these sites/facilities. 4.C. A process for addressing chemical site and transportation security to include conducting a Security Vulnerability Assessment (SVA). 4.D. A process providing manufacturer/supplier guidance and information to customers, warehouses, terminals, and/or carriers on procedures for loading, unloading, and/or storing chemicals, and a process to increase awareness of hazards from mixing incompatible chemicals. 4.E. 4.F. Documentation of current operating procedures for handling and storing chemicals. Procedures for ensuring that containers and transportation equipment are appropriate for the chemical being shipped, comply with regulatory requirements, and are free from leaks and visible defects. 4.G. Criteria for the inspection, cleaning, return, re-conditioning and re-use of containers and transportation equipment, and the proper disposal of cleaning residues. 4.H. Procedures to properly label and mark packages and containers. 4.I. 4.J. 4.K. Procedures for loading and unloading chemicals at the member company s facilities, and where appropriate the filling of containers, that result in protection of personnel, a reduction in emissions to the environment, and an increased awareness of hazards from mixing incompatible chemicals. Procedures for loading/unloading at customer sites addressing safety, security, and fitness. Provisions for control of processes and equipment during emergencies resulting from natural events, utility disruptions, and other external conditions.
CODE V: Job Procedures and Training 5.A. 5.B. 5.C. 5.D. 5.E. Identification of the skills and knowledge necessary to perform each job. Establishment of procedures and work practices for safe operating and maintenance activities. Training all personnel to reach and maintain proficiency in safe work, security practices, skills, and knowledge necessary to perform their job including confirmation of competence. Programs designed to assure that personnel in safety critical jobs are fit for duty and are not compromised by external influences. Members shall have a process in place to inform contractors of the known hazards and the emergency and/or evacuation plan. CODE VI: Waste Management and Resource Conservation 6.A. 6.B. 6.C. Procedures to ensure that all self-generated waste and empty containers are disposed of in a responsible manner and in accordance with existing regulations. A commitment through policy communications, resources, and programs to ongoing waste reduction and pollution prevention at each facility. A commitment to institute resource conservation measures. CODE VII: Emergency Response and Public Preparedness 7.A. 7.B. 7.C. 7.D. 7.E. Recognition & Prevention. Processes, policies, and/or procedures that address recognizing the potential for and preventing incidents and chemical releases resulting from man-made or natural events such as spills/leaks, fire, natural disasters, terrorism, cyber security threats, etc., involving the member company s facility or chemicals. Notification, Reporting, & Response. Processes, policies, and/or procedures that provide notification, reporting, and response actions by member company s personnel and/or contractors involving chemical releases on-site, or off-site transportation incidents and other potential incidents, including security. Preplanning & Coordination. Processes, policies, and/or procedures communicating potential hazards to response agencies about the site s facility and physical/chemical hazards as well as pre-planning for appropriate response to such hazards. Training. Processes, policies, and/or procedures to ensure appropriate training of personnel for emergency response and incidents and that their response actions are appropriate based on their level of training. Investigation and Corrective Action. A process for investigating incidents (including near-misses) that resulted or could have resulted in chemical releases or security compromise, and the implementation of appropriate preventive measures and/or corrective actions.
7.F. Annual Review, Testing, and/or Assessment. Operability of the written emergency plans. This may include a facility s emergency action and fire prevention plan and/or emergency response plan and/or security plan. 7.G. Facility Tours. Promoting the initial and periodic facility tours for first responders to promote emergency preparedness and to provide current knowledge of facility operations. 7.H. Participation. Coordination with the Local Emergency Planning Committee s (LEPC) process or other community organization involved with emergency preparedness and planning functions. CODE VIII: Community Outreach 8.A. 8.B. 8.C. Interaction with organizations, associations, government officials, and/or the public on behalf of NACD s Responsible Distribution. Information and updates for employees on Responsible Distribution and to encourage key employees to become involved in community outreach efforts. Advocacy of responsible public policies and regulations for chemical distribution. CODE IX: Product Stewardship 9.A. 9.B. A process to qualify customers as prescribed by governmental regulations. Member company should work with stakeholders to foster appropriate dissemination of information on the safe use, secure handling, and proper disposal of products commensurate with product risk. CODE X: Internal Audits 10.A. Member companies shall establish documented procedures for scheduled internal audits that verify implementation of the member company s policies and procedures supporting the Responsible Distribution. These audits shall be conducted on an annual basis at each member company location used for the distribution of chemicals to evaluate the effectiveness of the policies and procedures and conformance with the Responsible Distribution Code of Management Practice. 10.B. Audits shall be recorded and results brought to the attention of appropriate management personnel who must take timely corrective or preventive action. Any corrective or preventive action taken to resolve the cause of Responsible Distribution implementation inadequacy shall be appropriate, as determined by member company management, to the magnitude of the cause or inadequacy and commensurate with the risk involved. Responsible Distribution audit results shall be retained for at least three years. CODE XI: Corrective and Preventive Action 11.A. Member companies shall establish corrective and preventive action procedure(s) for Responsible Distribution-related issues, including the reviewing of actual and potential nonconformities, identifying causes of these nonconformities, identifying actions to be taken, and implementing
actions to prevent recurrence of nonconformities. Any corrective or preventive action taken to resolve the cause of the nonconformity shall be appropriate, as determined by member company management, to the magnitude of the cause or inadequacy and commensurate with the risk. 11.B. Member companies shall determine that actions taken were effective and share key findings and associated corrective and preventive actions with relevant stakeholders. CODE XII: Document and Records Control 12.A. Member company shall establish and maintain a documented system to control all policies, procedures, forms and records supporting Responsible Distribution. 12.B. A master list or functionally equivalent document control system identifying the current version of each document shall be established and be readily available to preclude the use of invalid and/or obsolete documents. Documents and documented procedures shall: be legible and readily identifiable; indicate relevancy of documents and appropriateness for all member company and contracted sites; include provisions for review and approval of any new or revised policies and procedures by the authorized personnel within the member company prior to issue; identify those of external origin; and identify those of controlled and external distribution. CODE XIII: Security 13.A. Leadership Commitment. Senior leadership commitment to continuous improvement in security through published policies, provision of sufficient and qualified resources and established accountability. 13.B. Analysis of Threats, Vulnerabilities and Consequences. Prioritization and periodic analysis of potential security threats, vulnerabilities and consequences using accepted methodologies. 13.C. Implementation of Security Measures. Development and implementation of security measures commensurate with risks, and taking into account inherently safer approaches to process design, engineering and administrative controls, and prevention and mitigation measures. 13.D. Information and Cyber-Security. Recognition that protecting information and information systems is a critical component of a sound security management system. 13.E. Documentation. Documentation of security management programs, processes and procedures. 13.F. Training, Drills and Guidance. Training, drills and guidance for employees, contractors, service providers, value chain partners and others, as appropriate, to enhance awareness and capability. 13.G. Communications, Dialogue and Information Exchange. Communications, dialogue and information exchange on appropriate security issues with stakeholders such as employees, contractors, communities, customers, suppliers, service providers and government officials and agencies balanced with safeguards for sensitive information. 13.H. Response to Security Threats. Evaluation, response, reporting and communication of security threats as appropriate
13.I. Response to Security Incidents. Evaluation, response, investigation, reporting, communication and corrective action for security incidents. 13.J. Audits. Audits to assess security programs and processes and implementation of corrective actions. 13.K. Third-Party Verification. Third-party verification that, at chemical operating facilities with potential off-site impacts, companies have implemented the physical site security measures to which they have committed. 13.L. Management of Change. Evaluation and management of security issues associated with changes involving people, property, products, processes, information or information systems. 13.M. Continuous Improvement. Continuous performance improvement processes entailing planning, establishment of goals and objectives, monitoring of progress and performance, analysis of trends and development and implementation of corrective actions.