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Canadian Chemical Producers Association

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29 Jun 2007 The Operations Integrity managing framework and managing systems address Employees at Sarnia site were recipients of the EMC RC award in

    Canadian Chemical Producers' Association

    Responsible Care? Re-verification 2005 - 2008

    of

    Imperial Oil Chemicals

    May 14 -16, 2007

    DISCLAIMER

This document has been produced by a team convened by the Canadian Chemical Producers'

    Association (CCPA) to provide guidance to the above company, as a member or partner of the

    association, in meeting its obligations under Responsible Care. The material in it reflects the

    team's best judgement in light of the information available to it at the time of preparation. It is the

    responsibility of the CCPA member or partner company which is the subject of this report to

    interpret and act on the findings and recommendations in this guidance document as it sees fit.

    Any use which a third party makes of this document, or any reliance on the document or

    decisions made based upon it, are the responsibility of such third parties. Although CCPA

    members and partners are expected to share the results of this guidance document with

    interested parties, the association, its member and partner companies, their employees,

    consultants and other participants involved in preparing the document accept no responsibility

    whatsoever for damages, if any, suffered by a third party as a result of decisions made or actions

    based on this report.

? Responsible Care is a registered trademark of the Canadian Chemical Producers' Association

    Responsible Care Re-verification; Imperial Oil Chemicals

    EXECUTIVE SUMMARY AND TEAM CONCLUSIONS

    A Responsible Care re-verification for Imperial Oil Chemicals was conducted on May 14, 15 and 16, 2007 in accordance with the Canadian Chemical Producers! Association (CCPA) 2005 -2008 Re-verification Protocol. Sites visited included Imperial Oil's Corporate Headquarters in Calgary, Alberta and their manufacturing site located in Sarnia, Ontario. A three-member CCPA appointed team conducted the re-verification, augmented by a Sarnia based local community representative. It included interviews with a cross section of corporate and local management as well as maintenance, production, and union personnel. The re-verification team also met with members of the local Sarnia Community Advisory Panel (Bluewater CAP). Various company documents were reviewed to confirm that the expected management systems were developed and implemented.

    This re-verification team found that the Responsible Care ethic, as it pertains to internal environmental, health and safety issues and to the externalization of Responsible Care is entrenched in Imperial Oil Chemicals' management system. The management team confirmed that Responsible Care principles and codes of practice have been incorporated into the company's internal standards, programs, practices and management system in a manner that guides the daily actions and decisions of the total organization. While opportunities exist for promoting the Responsible Care? brand both internally and externally, the Executive Contact is involved in the commitment to and the process of Responsible Care and is leading a sound approach to making it even more widespread across Imperial Oil Ltd. The entire management team was very positive towards the re-verification process, seeking the team's comments and suggestions towards their objective of continuously improving their Responsible Care Management system and performance.

    While there are still, as always, opportunities for improvement, the team found the company's overall management system to be self-healing, seeking to continuously improve, to identify deficiencies and committed to correct them in a timely manner consistent with the expectations of the company's stakeholders, employees, peers, and governments. The team has therefore signed off on this re-verification and recommends that CCPA officially recognize this re-verification with an award at the next: suitable occasion.

Signed: A. M. Robertson Date: June 29, 2007

     Team Leader

    For more information on this or a previous re-verification or on the company's original report for verification of Responsible Care-in-Place, please contact your local company site or the company's overall Responsible Care coordinator Peter Forristal, telephone (403) 237-4149, e-mail peter.m.forristal@esso.ca

    Re-verification report for Imperial Oil Chemicals, May, 2007 Page 2 of 44

Summary of Findings, Opportunities, Best Practices and Extra Miles

    This section of the report lists all Findings Requiring Action, Opportunities For Improvement, Best Practices and Extra Miles found in the body of the text. In all, the team recorded 2 findings and 31 Opportunities for Improvement. Progress on action to resolve the Findings will require follow-up at each Leadership Group Meeting, with the local CAP, in the company‟s annual CEO re-commitment to

    CCPA, and, along with the decisions pertaining to the Opportunities, in the next Responsible Care re-verification. The wording of each Finding Requiring Action, Opportunity and other comments found in this Executive Summary is identical to the wording used in the body of the report to avoid any possible

    misunderstanding of the team‟s intent.

Findings Requiring Action

3 k)

    A finding requiring action is that the company needs a managing system in

    place to confirm that all carriers involved from the shipping point to the

    customer destination have adequate security systems in place conforming

    to the company’s needs. This includes third party contract road carriers

    and short haul railroads.

3 l)

    IOL waste carriers and terminals are currently being evaluated by QRC

    every three years. A finding requiring action is that these carriers and

    terminals be assessed every two years in accordance with the CCPA

    standard.

Opportunities for Improvement Currently In IOL Plans

2 c)

    1/ Imperial Oil Chemicals conducted extensive reviews and risk assessments following the MEK spill incident. The company is encouraged to complete the

    installation of upgrades to the once through cooling water system and associated facilities, in accordance with their current plans.

3 a)

    2/ An opportunity for improvement exists by extending, as currently planned, the pipeline management system to include all supplier pipelines to customer sites (including non-owned sections of pipelines) with the objective of ensuring that they have the same degree of ongoing maintenance management that Imperial

    Oil Chemicals’ provides to their own pipelines.

    3/ The company is encouraged to continue their current dispersion modeling examination of liquid and heavier than air release safety valves, initiated as a result of recent fire/explosion experiences elsewhere by such releases.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 3 of 44

3 b)

    4/ The company is encouraged to complete the outstanding items from the most recent security vulnerability analysis (SSQRA) in the near future as currently

    planned.

3 d)

    5/ The Company is encouraged to provide ongoing support towards the development and implementation, under governmental leadership and guidance,

    of a Sarnia community health study strategy.

3 f)

    6/ The company is encouraged to implement a seat belt wearing improvement initiative from education through monitoring and formal corrective action as currently planned.

3 g)

    7/ IOC are encouraged to pursue the current initiative of having a direct call system to the CVECO emergency command centre as currently planned.

3 m)

    8/ An opportunity for improvement is for the company, in concert with other area CCPA member companies, to continue their initiative towards using the area

    TransCAER Fair approach for training emergency responders across the

    Province of Ontario.

New Opportunities for Improvement

2 b)

    9/ An opportunity for improvement exists through identification of the root cause(s) for OI audit findings not being completed within established deadlines with the objective of improving the process so that deadlines set are realistic, achievable and met except in the rare cases when unforeseen extenuating

    circumstances dictate otherwise.

2 d)

    10/ The company is encouraged to expedite use of the “IMPACT” system to track all follow-up items from audits, inspections, and meetings in addition to its current use for incident investigations. The system should also cover "issues" as well as incidents: for example, any concern the community or other stakeholder has

    should be tracked in the same way as an incident.

3 a)

    11/ An opportunity for improvement exists by involving plant operating and maintenance workers in facility revision and new construction projects to help ensure that operability and maintainability aspects are thoroughly considered

    before designs are finalized.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 4 of 44

    12/ There is an opportunity for improvement by having a management system in place to ensure that toll processors management systems for contracted

    operations performed for Imperial Oil Chemicals meet the guiding principles of

    the manufacturing code of practice.

3 b)

    13/ A potential opportunity for improvement exists through participation in CCPA’s Security Task Force.

    14/ An opportunity for improvement exists for the Sarnia site to implement a documented process to periodically test that immediate neighbours within the site

    Worst Case Scenario perimeter know how they will be informed of and what to

    do in case of a facility emergency involving shelter in place. Continuous

    improvement initiatives should be developed based on test results.

3 c)

    15/ An opportunity for improvement exists for the company to build into its management system a process for ensuring that distributors, toll processors and

    third party operated bulk transfer and repackaging facilities have adequately

    informed their neighbours and first responders of possible emergencies and the

    appropriate course of action in such events.

    16/ An opportunity for improvement is to establish a validation process to ensure that CCPA and CACD members, who are suppliers and distributors to IOL, are in

    fact following through on actions arising from those respective association’s

    verification processes. Membership in those organizations by itself is insufficient

    evidence of acceptable performance.

3 e)

    17/ An opportunity for improvement exists for Imperial Oil Chemicals to emphasize the “branding” of Responsible Care as an industry-wide ethic, with a

    broader scope than OIMS, in employee training programs.

    18/ The external “branding” of Responsible Care as an overall industry culture with its common industry ethic is a key message needed to be promoted within

    Imperial Oil Chemicals’ operating communities and throughout the company’s

    stakeholders.

    19/ An opportunity for improvement exists for Imperial Oil Chemicals to post CCPA Responsible Care signage such as the Responsible Care banner and

    Commitment signed by the Senior Executive Contact prominently at plant sites.

    20/ During our interview session with the Employee Health and Safety Committee representatives, they asked that they receive a copy of this re-

    verification report.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 5 of 44

3 f)

    21/ An opportunity for improvement exists by having the Sarnia plant safety orientation video reviewed by people who represent a cross section of the target audience to ensure that the message is given clearly, with appropriate

    transitioning from one topic to the next so that the expected outcomes are

    realized.

    22/ An opportunity for improvement exists through reviewing the decision to remove exercise equipment from control rooms with respect to their use in

    keeping operators alert by exercise during night shifts.

3 g)

    23/ The team suggests that OIC test their current process for keeping their

    neighbour list up to date to validate the effectiveness of the system in achieving this objective.

3 h)

    24/ An opportunity for improvement exists, in the company’s standard for identifying new neighbours, to use language and a process that is more

    aggressive in requiring the identification and informing new neighbours of risk

    and emergency procedures (e.g. via CAER pamphlets to those newly arriving via

    the Sarnia Real Estate Board).

3 i)

    25/ An opportunity for improvement exists through tracking of the supply chain back to the source of components to have IOL social responsibility expectations

    considered in purchases.

3 l)

    26/ An opportunity for improvement is to work with marine shipping companies to ensure that MSDS’ are provided in the languages of workers involved in ship

    loading/unloading and surveying operations. (Note- ship workers native language

    is potentially different than on board MSDS documents and frequently different

    from that of the Captain).

    27/ There is an opportunity for improvement by working with marine shipping companies to ensure that management systems in place adequately protect

    surveyors and ship personnel from product exposures while performing cargo

    surveying and loading/unloading operations.

    28/ An opportunity for improvement is to have a process in place to monitor the EHS performance on marine vessels contracted to carry IOL products.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 6 of 44

29/ An opportunity for improvement is to encourage “class one” railroads to have

    a management system in place, which includes a Responsible Care reference,

    for short line railways to whom IOL products are handed over.

30/ An opportunity for improvement is to encourage”Tandet” (primary road

    carrier) to get involved in the Sarnia area transportation/community committee.

31/ An opportunity for improvement is to have a management system in place

    which ensures that the protocols used by IOL personnel for motor carrier

    assessments are maintained current vs. the CCPA protocol and that assessors

    have the required knowledge and experience to effectively perform this work.

Best Practices

2 a)

    Imperial Oil Chemicals active leadership and support to the CCPA through

    participation in various committees and initiatives is a industry best practice

    2 e)

    The team was impressed with the broad scope of measurements used to monitor

    the effectiveness of their management system and consider it a best practice.

3 a)

    The team considers the company‟s Operations Integrity Management System

    combined with the Operations Integrity Steering Committee‟s focus on

    Responsible Care performance to be an industry best practice.

The Global Reliability System (GRS) has been built with a very strong Plan-Do-

    Check-Act philosophy that complements the Company's OIMS. The team

    considers the introduction of a strong management system around reliability and

    maintenance performance to be an industry best practice.

The company has recognized the need to address the transition in the workforce

    demographics which potentially involves the loss of operational and safety

    expertise due to the upcoming retirement of long time expert personnel in these

    areas. The GRS will also help to ensure retention of such expert knowledge.

3 c)

    The supply efficiencies initiative which has reduced greenhouse gas emissions in

    addition to achieving cost savings for Imperial Oil Chemicals is an industry best

    practice.

3 d)

    The company‟s Environmental Risk Management process is an industry best

    practice

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 7 of 44

The team considers the Essentials of Environmental Excellence (EEE) Training

    program to be an industry best practice.

3 f)

    The company‟s comprehensive OI and OH&S management systems are an

    industry best practice.

3 l)

    Imperial Oil has a well defined rail car maintenance management process in

    place which the team considers a best practice.

3 m)

    The company‟s very strong leadership and involvement in TransCAER outreach

    is a best practice

Extra Mile

3 d)

    The leak detection and repair (LDAR) program at the company‟s Sarnia

    aromatics unit is an “extra mile”.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 8 of 44

INTRODUCTION AND OVERVIEW

    1a) The company

    This is the report by the verification team on those operations of Imperial Oil

    Chemicals which are covered by the company‟s commitment to the Responsible

    Care initiative of the Canadian Chemical Producers' Association. A description of

    the company in Canada and which operations are covered by this report can be

    found in Appendix 1.

    1b) Responsible Care

    Responsible Care is an initiative of the Canadian Chemical Producers'

    Association (CCPA) by which the association‟s members and partners commit to

    be, and to be seen as, responsible companies within Canadian society. It is

    based on an ethical approach to the safe and environmentally sound

    management of chemicals - an approach which started in Canada but has since

    spread to over 45 countries around the world.

    The Responsible Care Ethic:

We are committed to do the right thing and be seen to do the right thing.

    We are guided towards environmental, societal, and economic sustainability by

    the following principles:

    ? We are stewards of our products and services during their life

    cycles in order to protect people and the environment.

    ? We are accountable to the public, who have the right to

    understand the risks and benefits of what we do and to have

    their input heard.

    ? We respect all people.

    ? We work together to improve continuously.

    ? We work for effective laws and standards, and will meet or

    exceed them in letter and spirit.

    ? We inspire others to commit themselves to the principles of

    Responsible Care.

    The ethic is supported in Canada by six codes of practice covering relations with

    the communities where members‟ facilities are located and also responsible

    management throughout the product life cycle. Information on these codes of

    practice and related activities is available from company personnel listed in

    Appendix 2 of this report, or via the CCPA web site www.ccpa.ca (click on the tab

    for Responsible Care).

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 9 of 44

    1c) Expectations of CCPA members and partners

    Each CCPA member or partner company must formally commit to the ethic,

    principles and codes of practice of Responsible Care as a condition of

    membership in the association.

Progress in implementing these obligations must then be reported to CCPA, both

    to peers at special networking meetings and also via a formal reporting system to

    the association. Three years is the typical time allowed to new members for

    implementation. The association monitors progress and follows up by arranging

    for assistance where necessary to ensure that each company eventually meets

    its commitment.

When a company considers that its management processes are sufficiently

    comprehensive that they meet each of the 151 individual code requirements, it

    advises the association that implementation is complete to the stage of

    “Responsible Care-in-Place”. Completion in this sense does not imply that

    nothing further needs to be done, but that a key milestone has been reached in a

    process of continuous improvement.

    1d) Verification

    A company‟s declaration that the expectations of Responsible Care are being

    met is an important first step in the verification process, which leads to

    confirmation and recognition of this by a team of industry and public

    representatives. Verification is conducted to strict protocols, developed by the

    association‟s members and others including several critics of the chemical

    industry and its operations. The first verification takes place when the company

    first states that its performance meets the expected level (Responsible Care-in-

    Place). This verification is designed to confirm, for the company‟s peers in CCPA

    and the public, the existence of a company wide ethic and management systems

    which ensure that the principles and codes of practice of Responsible Care are

    not only in place but are also practised and continuously improved within the

    organization.

Subsequent verifications are also conducted using a different protocol,

    approximately every three years after formal acceptance of the first verification,

    to ensure that the ethic and management systems of Responsible Care are firmly

    rooted in all the company‟s operations. This is known as re-verification.

Each verification is conducted by a team consisting of:

    ? knowledgeable industry experts with experience in Responsible Care;

    ? a representative of the public at large (usually with a public interest

    background and with experience in Responsible Care gained from serving on

    the CCPA‟s national advisory panel) and

    ? one or more representatives of the local communities where the company‟s

    facilities are located.

Re-verification report for Imperial Oil Chemicals, May, 2007 Page 10 of 44

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