Chemical Week • July 3/10 • Collective commitment: Responsible Care charts course for sustainable future

Responsible Care remains industry’s operational ethos for environmental, health and safety in its 37th year in the US. The program’s commitment to continuous improvement shows no signs of slowing with the recent decision to add sustainability metrics as a program requirement.

The decision to add sustainability metrics to Responsible Care certification requirements is a natural evolution of the program, which has long included transparent reporting of environmental performance as an element of responsible operations. The new metrics — which build on existing reporting for air emissions, water usage and releases, and climate and energy intensity — are a codification of voluntary sustainability principles the American Chemistry Council, Inc. (ACC) introduced three years ago.

Mitch Toomey, vice president of sustainability and Responsible Care at ACC, said the board decision to incorporate additional sustainability metrics represents a “consensus of membership” that sustainability is part of its core mission. “I think we’re at a pivot point, not just as an industry but as an economy, where talk about the environment and lofty ambitions are advancing to implementation,” he said. “As the world transitions to this new economy, ACC and its members are focused on making sure that we as an industry secure our license to grow and thrive in the midst of uncertainty.”

When Toomey joined ACC in September 2022, there was already a robust effort underway to evaluate how progress was being measured across numerous and ambitious sustainability programs and what ACC could do to promote a uniform measurement scheme for the sector. In addition to being “the right thing to do,” ACC wants to ensure industry’s sustainability efforts would be reflected in a mandatory system of record. “We have to show that we are doing the work necessary to pursue sustainability in our own operations and make that mandatory for membership, but at the same time recognize that sustainability also reflects a lot of other pursuits our members are making,” he added.

Chemical industry sustainability programs fall into three areas, he said. “There are sustainability efforts a chemical company is responsible for within their facility — carbon footprints, emissions, water usage, etc.” he said. Such measurements have long been part of the fenceline environmental requirements already within Responsible Care. “But we also have a responsibility to look at sourcing. And that’s a very different pursuit, requiring a deep look at procurement and planning. And then there’s sustainability downstream; there is a lot of new product innovation underway to satisfy customer demands that drive sustainability in the customer space.”

He sees a “clear urgency” for industry to be recognized as a sustainability leader across all three. “If you look at these three zones of sustainability, Responsible Care is really what we do within our fenceline and communities,” he said. “So, we don’t see it as something that is completely contained within Responsible Care because the subject of sustainability will unfold in very interesting ways in the commercial space.”

Daryl Roberts, chief operations & engineering officer at DuPont, and member of ACC’s board, said the board will continue to look at relevant sustainability and environmental, social and governance (ESG) metrics to add to the program over time. “We started by picking a limited number of metrics for sustainability to move into mandatory Responsible Care reporting and we’ll continue to look at relevant metrics that might be helpful to add. We’ve taken the first step and I could see us going further in that direction over time. We want to take some time and see how the first set of reporting requirements goes before deciding what the next group will be.”

There are several benefits to boosting reporting requirements within Responsible Care. The collective commitment could help industry avoid potentially unworkable or counterproductive regulatory schemes down the road. “We know our business better than anyone, so we wanted to make sure we are getting ahead of issues that might arise in the future,” Toomey said. “Some have described sustainability as a slow-motion safety issue, and [under the charter of Responsible Care that constitutes] a risk we are obligated to mitigate.”

There is also an opportunity for the chemical industry to establish itself as a “knowledge partner” for other industries, raising industry’s profile as a leader in sustainability, he said. “Responsible Care has been measuring sustainability [within fencelines] for 20 years. Some of these metrics, like greenhouse gas emissions, are things companies in other industries are just starting to figure out how to measure. We’ve been doing that a long time. We have a lot to offer.”

Data collected from the new metrics could also help in developing a scheme for measuring Scope 3 emissions — a complex task for any sector, but especially unwieldy for a sector as interconnected as chemicals. ACC does not yet have a position on a preferred system, saying the science is still being developed. “Our message to entities attempting to quantify Scope 3 is that we encourage the scientific pursuit,” Toomey said. “We believe that ultimately it is measurable.” He added that it takes decades to get to a point where you have a “30,000 foot view” of the data. “We’re just not there yet.”

Chemicals and materials innovation is key to enabling low-carbon and circular economies, but a clear definition of what sustainable chemistry is has to be established before legislators can regulate and incentivize. Brands and retailers also need a clear definition to guide formulation decisions.

Though separate from Responsible Care, ACC’s board also approved a set of sustainable chemistry principles in June that it hopes will ensure industry’s voice is heard on the matter. The result is a comprehensive but unrestrictive definition of sustainable chemistry that ensures industry innovation potential is not pigeonholed to the extent that meaningful innovations are unnecessarily sidelined.

“This isn’t just an academic or NGO exercise,” Toomey said. “The White House is stepping up as well. But the list of what is required for a chemical to be considered sustainable is growing, like some of the bloated reporting systems attempting to capture every aspect of sustainability.”

The first principle — having a holistic approach — balances the three elements of sustainability: environmental protection, social development and economic development. “Sustainable chemistry considers a broad range of factors to advance more sustainable products and processes,” according to ACC. “These include managing resource needs and potential impacts of products and processes on human health and the environment.” Toomey called this principle an evolution of the triple bottom line: People, Planet Profit.

The second principle emphasizes the need for life cycle and systems thinking; in other words, looking at a product’s entire life cycle and considering where does the product’s impact start, where does it end and how end-of-life impacts can be mitigated at the start. The third principle is designing for safe use by assessing safety using the best available scientific knowledge and weight of the evidence methods for evaluating scientific studies. The fourth principle emphasizes that sustainable chemistry fosters innovation. “We’re seeing it every day in new materials, new partnerships, and inventive ways to tackle issues like carbon footprint,” Toomey added.

Other sustainable chemistry definitions being kicked around include constraints and materials requirements that could distract from the core mission of sustainability and slow urgently needed progress. Chemical customers using such misinformed guidelines could end up steered away from better alternatives because they are looking for specifics such as a certain raw material. “Such decisions could ultimately hamper efforts to build a green economy,” Toomey added.

The addition of sustainability metrics is one of many additions and updates ACC has made as challenges and stakeholder expectations evolve. For example, security codes were implemented in the wake of the September 11 attacks, and product safety codes were added a decade ago, and updated in 2021, to address growing consumer interest in the safety of chemical products. ACC also continues to evaluate and update existing codes to ensure no stone is left unturned when it comes to responsible operations.

Recent updates to requirements on process safety — the issue Responsible Care was founded on nearly 40 years ago — are a great example. “The original code outlined a management system approach and focused on providing tools for how to build a culture for process safety, good leadership, and accountability. To that end I think it was very successful,” said Jim Muoio, global process safety and environmental health & safety/ reliability auditing director at Celanese and chairman of ACC’s process safety Committee, told CW. “When you think about driving excellence, you think about a management system process that has a continuous improvement aspect to it,” Muoio said. “Generally, this is kind of a ‘plan, do, check, act’ model.”

In 2016, ACC added the Enhancing Process Safety program, which sought to increase sharing of information about incidents and excellent examples; create events where process safety leads could meet in a protected forum to openly collaborate; and facilitate “responsible collaboration” with other organizations such as the Center for Chemical Process Safety (CCPS).

Publicly available data and Responsible Care metrics shows that Responsible Care companies were five times safer than the US manufacturing sector in 2020 and three times safer than the overall business of chemistry. But at the time ACC had also noticed that the pace at which process safety incidents were decreasing had roughly plateaued since 2010 — indicating an opportunity for improvement. This was among the reasons why ACC embarked upon a “soup-to-nuts” review of Responsible Care in 2020. Ten recommendations emerged in June 2021 from early results of the review, and process safety featured heavily. ACC also announced a goal to reduce Tier 1 incidents — defined as a loss of primary containment, with the greatest consequence by American Petroleum Institute’s (API) RP 754 — by 20% by 2025, a goal ACC characterized as “aggressive but achievable.”

Updates to the process safety codes that arose from the review included more action-oriented terminology, with well-defined exceptions and a focus on “what good looks like,” Muoio said. The effort also enhanced clarity and utility for plant operators and auditors. “While we thought the original process safety code was serving us well, it was written in somewhat of an aspirational tone,” he said. “The updated code is written in a much more actionable tone. We also discovered during the review that our smaller members were heavily relying on the process safety code to develop their process safety management system. So, we worked to expand and clarify the language.”

The updates also modernize the code to sharpen focus on leadership and action, as opposed to just having an administrative standard. “Improvements in the code require leadership to be directly engaged in process safety procedures,” Roberts said. “This includes data review and driving culture within the organization. The updates also clearly define the knowledge and expertise required for those making process safety decisions at Responsible Care sites.”

The updates also added clear functionality around information sharing. “Any type of event — even something that didn’t cause a release or an obvious outcome — is shared,” Roberts said. “That way we can apply those learnings to preventing future events at our sites, environments, and communities.”

Preventing safety incidents requires good hazard recognition, significant controls in place around those hazards, a technical method for evaluating the level of control needed and maintenance programs to make sure those systems are in place, Roberts said. “The auditing mechanism within Responsible Care is helpful to make sure you are operating in the safety window that you believe you are because the controls — be they administrative or engineering — are working as you expect. You really can’t do that without auditing.”

Though these programs are newly implemented, Roberts said ACC is already seeing the benefits. “Every year we expect to see the number of events trend in the right direction,” he said. “We had a list of companies that we identified as qualified for our Progressive Achievement Program … and 75% of those participants reduced their incident rates over the past 24 months. We set a goal of 20% reduction by 2025 and we’re trending in the right direction. And I think we’ll make that 20% reduction by 2025 target. And then we’ll set the next target.”

Member company feedback on the process safety code updates has been positive. “There’s full support within the industry and ACC member companies to continue to improve our focus on process safety,” Roberts said. “The feedback has been that the additions are helpful in making sure organizations are fully engaged from the C-suite down through the shop floor to ensure everyone is driving safety culture.

Looking ahead, artificial intelligence could emerge as a monitoring tool driving additional process safety performance. “We’ve been trialing different types of AI to look at the data, not just on a site level but also on an industry level,” Roberts said. “We haven’t quite found the right platform or data set yet, but we’re very excited about the potential for AI as a predictive measure that we may not have now.”

There is a business case for driving process safety in addition to the moral one — ”a safe plant is a reliable plant and a reliable plant is a safe plant,” Muoio said — but process safety excellence also helps industry maintain its license to operate in the community.

Industry’s impact and progress to safe operations, role in American manufacturing, and sustainable development contributions has never been more important. The US Environmental Protection Agency’s (EPA) increased focus on environmental justice and Beyond Petrochemicals — Bloomberg LP founder and former New York mayor Michael Bloomberg’s $85 million fund to block construction of planned US petrochemical projects — represent significant escalation of pressure campaigns against industry expansion.

Bloomberg’s program, announced in the fall of last year, aims to “turbocharge existing efforts led by frontline communities” to block the expansion of more than 120 proposed petrochemical projects in Louisiana, Texas and the Ohio River Valley. Combined, these three regions account for nearly all US cracker and resin investment. Beyond Petrochemicals cites toxic and carbon pollution from petrochemical plants and also notes that as economies transition to clean and renewable energy, demand for oil is projected to shift from fuels to petrochemicals. Beyond Petrochemicals said the groups it will coordinate with include Beyond Plastics, the Bullard Center at Texas Southern University, Defend Our Health, Earthjustice, Earthworks, Hip Hop Caucus, Louisiana Bucket Brigade and Rise St. James.

For its part, ACC is continually evaluating its levels of outreach to ensure communities understand how rigorous safety and sustainability elements are under Responsible Care. “We want the communities we are in to be reassured and understand the deep systems that we have in place,” Roberts said. “The Responsible Care codes go well past any regulatory requirement. It is really to make sure that our sites are not just focused on what they need to do to be compliant but that we’re doing things like making sure we have ongoing risk reduction and that we’re looking for alternate chemistry and alternate routes of manufacturing that will reduce the amount of chemicals that have to be moved into and used on our sites.”

Community Advisory Panels (CAPs) are the cornerstone of ACC’s community outreach efforts. “CAPs ensure we have leaders from the community involved. CAPs organize site tours so the community can see first-hand the rigorous systems we have in place,” Roberts said. “We also make sure that a significant number of hires are from within the community. These individuals have a vested interest in safety because they want their families, neighbors and overall community to be safe.”

Toomey said efforts are also underway to further promote and broaden understanding of Responsible Care. “There’s a newfound interest in responsible companies and responsible sourcing and we are looking to revitalize Responsible Care messaging to make sure it is relevant to communities.” It is also important for communities to understand industry’s commitment to them, he said. “As local issues are picked up by NGOs, we want the communities we operate in to understand that we are with them for the long haul, we are an integral part of the green economy, and we are integral to the future success of vital industries for the new economy.” Engagement with CAPs and transparency help industry maintain its license to operate, he added.

Ultimately, focus on safe operations, sustainability, and community engagement is vital to not only the chemical industry’s ability to thrive and innovate, but to driving the new green economy. “Without question, what we are doing is critical to the success of the nation from an economic standpoint, Roberts said. “And the products we are making, what ACC is doing as an organization, and Responsible Care are clearly aligned with ESG goals of our customers and communities. Sustainability will continue to be critical as we drive forward, and chemistry has a key role to play for the betterment of the planet.”