DISTRIBUTION IMPLEMENTATION EXAMPLES AND TOOLS David Sandidge Director, Responsible Care American Chemistry Council June 1, 2011

Code Elements Examples and Tools Regular Evaluation of Chemical Distribution Risks – Written Risk Review procedure – Formal Risk Review process Implementation of Risk Reduction Measures – Are additional risk reduction measures needed? – Formal follow up on action items Investigation and Corrective Action of Chemical Distribution Incidents – Develop formal incident reporting process – Issue and review formal incident report summaries quarterly Monitoring Changes and Interpretations of Regulations and Standards – Responsibilities established to monitor relevant regulations 2

Code Elements Examples and Tools Training for Affected Company Employees – Training matrices developed and utilized – Incorporate into existing training management systems Providing Guidance on Company Practices to Carriers, Distributors and Contractors – Web portals and toll free phone in place to provide information Regular Review of Compliance – Incorporate into internal audit program Process for Qualifying Carriers of all Modes and Types Feedback to Carriers on Their Performance 3

Code Elements Examples and Tools Selection and Use of Appropriate Packaging and Containment – Procedures in place Procedures for Loading, Filling and Packing that Will Reduce Emissions, Protect Personnel and Provide Secure Lading – Inspection of bulk containers Procedures for Unloading … – Pay attention to basics – blocking, bracing, fittings, inspections Defined Criteria for Cleaning and Return of Equipment and Disposal of Cleaning Materials 4

Code Elements Examples and Tools A Program for Providing Guidance and Information on Proper Unloading and Storage Procedures – Outreach to receivers, including visits from Mat’l Handling A Process for Selecting and Approving Distributors and other Facilities that Store or Handle Chemicals – Develop qualification checklists based on risk and mode Feedback to Distributors and other Facility Operators on their EHSS Performance – For major Distributors, formal visits and performance reviews A Process for Responding to Chemical Distribution Incidents – Need a communications network including key contacts 5

Code Elements Examples and Tools Procedures for Making Chemical Information Available to Emergency Responders – Emergency response information is distributed and understood Program for Making Facilities / Training Available to Emergency Responders – Outside responders participate in joint drills with company Dialogue with Emergency Planning Organizations Dialogue with the Public – Include Logistics information with CAER information 6

Distribution Code Implementation General Insights Potentially complex due to the different logistics modes Significant outreach to carriers and other supply chain partners Logistics procurement function can play a key role Reward cooperation and performance Good material handling habits begin at your facility Risk based – product, mode, route 7