EXECUTIVE SUMMARY

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The main portion of the Responsible Care-in-Place verification of PDI-Polymer Distribution Inc. was conducted on November 16, 17 and 18, 2009.

The verification was based on visits to company operations at Guelph, Ontario, Edmonton, Alberta and Mississauga, Ontario. Information was gained from interviews and inspections at these sites. The verification was conducted by a three-person team assisted by a local community representative from Guelph. Telephone discussions were also conducted with a selection of customer and municipal emergency response representatives.

The team used the top-down questioning approach described in the Responsible Care-in-Place Protocol. The questions focused on process rather than detail, and tested for the existence of effective management systems to ensure understanding of Responsible Care, establishing and meeting the desired level of performance, documentation and adequate resourcing.

The team found that the company has progressed well with Responsible Care implementation and is close to meeting the requirements for Responsible Care-in-Place. For the most part effective practices are in place, enabling the company to meet and sustain the desired level of performance with provision also for continual performance improvement.

Several examples were found where the company  applied innovative systems (i.e., best practices), which could be useful for other CCPA Transportation Partners, and the company is encouraged to share these via the CCPA Leadership Group in which it participates or other appropriate means. These are listed below:

• The practice of checking safety showers for proper operation prior to handling hazardous chemicals;
• The practice of placing dust collection bags on top of dry bulk tankers to prevent escaping dust during loading;
• The comprehensive environment, health and safety hazard analysis that has been conducted for all company fixed facilities, which includes the identification of operational hazards, the potential impact of those hazards, and the control measures required to mitigate same;
• The computerized vehicle maintenance program, which automatically identifies the timing for scheduled maintenance, annual safety inspections, etc.;
• The proposed mobile communications system which will provide global positioning system tracking of all trucks, automated hours of service for all drivers thus ensuring regulatory compliance, reporting of safety parameters (e.g., hard braking and speeding) and provide fuel economy data which can be used for  emissions monitoring; and
• The plan in place to retrofit all warehouses with high intensity low energy lighting.
• The following items, defined as Findings Requiring Action, are where additional effort is required for Responsible Care-in-Place to occur:
• Prepare a document that describes the company’s integrated Responsible Care Management System in terms of the plan-do-check-act continual performance improvement cycle. In the document identify those processes, procedures, etc. that support each element of the cycle, including how they are accessed;
• Close gaps in the existing cross-reference document where specific company processes, procedures, etc. have not been identified to address all of the requirements of the transportation partners’ model for Responsible Care. (e.g., management of change, environmental protection, risk assessment and community dialogue);
• Update the existing auditing process to address those processes, procedures, etc. (i.e., as identified in the completed cross reference document) that support all of the requirements of the transportation partners’ model for Responsible Care;
• With respect to public safety and potential environmental impact, identify worst case operational incident scenarios for all transloading terminals, warehouses and packaging facilities (e.g., release of hazardous materials, dry bulk materials fire, etc.);
• With respect to public safety and potential environmental impact, specifically identify those locations or areas, throughout the company’s trucking routes, where accident risk potential would be significantly greater than that which would be considered as normal, and identify related worst case scenarios.
• Typical aspects for assessment could include proximity to communities, cargo hazards, quantities shipped, traffic volume, etc.
• (Note: Proposed new mobile communications system may be of assistance in determining those high risk locations);
• Prepare and implement a document that describes an operational risk assessment standard, procedure and schedule for on-going assessments;
• Establish a process to analyze incident data for repeating patterns of events (e.g., types of incident/injury, root causes, etc.) including identification of preventive actions and follow-up to ensure effective implementation; 
• Prepare and implement a document that describes a process for assessing the risks of new products being accepted for transportation and the development of handling procedures  prior to any transloading activity commences;
• Prepare and implement a document that describes a buffer zone policy and process to proactively monitor for possible rezoning applications and encroachment of inappropriate land use at all company facilities;
• Prepare and implement a document that describes a process for review and approval of changes to fixed facility and transportation equipment and procedures to ensure that new unacceptable risks are not built into the operation;
• Incorporate a process into the maintenance materials management system to ensure that only “replacement in kind” parts can be used with no substitutions allowed;
• Prepare and implement a document that describes a process for the assessment of new customers with respect to their environment, health and safety commitment and past performance;
• Prepare and implement a document that describes a process for the selection of suppliers of hazardous materials (e.g., fuel, hydraulic oils, solvents, etc.) and service providers (e.g., contracted shops, waste management facilities and their carriers, road tank washing facilities etc.) with respect to their environment, health and safety commitment and past performance;
• Prepare and implement a document that describes a process for regular monitoring of all customers as to their on-going environment, health and safety performance;
• Prepare and implement a document that describes a process for the regular monitoring of suppliers of hazardous materials (e.g., fuel, hydraulic oils, solvents, etc.) and service providers (e.g., contracted shops, waste management facilities and their carriers, road tank washing facilities, etc.) as to their on-going environment, health and safety performance;
• Prepare and implement a document that describes a process for the assessment of any motor carriers directly contracted by the company with respect to their environment, health and safety commitment and past performance;
• Prepare and implement a document that describes a process for regular monitoring of any motor carriers directly contracted by the company as to their on-going environment, health and safety performance;
• Prepare and implement a document that describes a security assessment and management standard for all fixed facilities and trucking operations;
• Establish a process to maintain an up-to-date listing of immediate neighbours around all facilities;
• Prepare and implement a document that describes the company’s overall management system for all aspects of community awareness and dialogue at all levels of the organization;
• Prepare and implement a document that describes the specific community dialogue process for all individual fixed facilities and transportation routes, including the requirement that this dialogue process be done periodically;
• Establish a process for on-going involvement in the CCPA TransCAER initiative;
• Establish a plan and timetable to advise individual members of communities adjacent all fixed facilities where there is the potential for them to be adversely impacted by operational incidents. Communications should include what to do in an emergency. This should be done in collaboration with municipal emergency organizations;
• Establish a plan and timetable to advise individual members of communities, where there is the potential for them to be adversely impacted by vehicle accidents or other operational incidents, at those locations where accident risk potential has been identified as being significantly greater than that which would be considered as normal. Communications should include what to do in an emergency. This should be done in collaboration with municipal emergency organizations;
• Prepare and implement individual documents that describe the company’s emergency preparedness and response plans for all fixed facilities and trucking operations;
• Establish a process to regularly test all emergency preparedness and response plans;
• Integrate emergency preparedness and response plans with municipal agencies at all locations;
• Establish a process to carry out emergency preparedness and response drills with municipal agencies at all locations;
• Prepare and implement a documented integrated emergency preparedness and response plan with railway companies at each railway transloading site;
• Integrate tenants into emergency preparedness and response planning at locations where the company has tenants at its facilities;
• Prepare and implement a document describing the company’s policy for addressing the needs of persons dislocated by an emergency situation involving company operations; and
• Include in a debriefing process in emergency preparedness and response plans that, following an actual emergency or exercise, assesses the effectiveness of the response and initiates appropriate updates to the plan.

Several other recommendations, defined as Improvement Opportunities, were made by the team but not considered essential for Responsible Care-in-Place.

All of the above are identified within the body of the report and listed in section 2.

The team will follow-up with the company as to when and how closure on the above outstanding Findings Requiring Action will occur, and subsequent award of Responsible Care-in-Place.

Given the extent of work involved it is suggested that consideration be given to the assignment of additional resources, over and above that currently available, to facilitate timely closure on the above.

Dave Mack
Verification Team Leader
February 15, 2010

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