Responsible Care® : Codes of Management Practices 

Chemical Manufacturers' Association

Community Awareness and Emergency Response
Pollution Prevention
Process Safety
Distribution
Employee Health and Safety
Product Stewardship

Community Awareness and Emergency Response 

Purpose

The goal of the Community Awareness and Emergency Response (CAER) Code of Management Practices is to assure emergency preparedness and to foster community right-to-know.  It demands a commitment to openness and community dialogue.  The code has two major components:  first, to assure that member facilities that manufacture, process, use, distribute or store hazardous materials initiate and maintain a community outreach program to openly communicate relevant, useful information responsive to the public's questions and concerns about safety, health, and the environment; and second, to help protect employees and communities by assuring that each facility has an emergency response program to respond rapidly and effectively to emergencies.

The community outreach component will communicate program activities and performance under all codes of management practices and will promote an open, ongoing dialogue with employees and the community.  Information should be provided about such activities as waste minimization, emission reduction, health effects of chemicals, and efforts to ensure the safe transport of chemicals.

The CAER Code of Management Practices is supported by, and will build on, CMA's CAER process.  CAER supports the community's right to know about chemical industry operations and their effect on safety, health, and the environment.  CAER originally was a voluntary initiative focused on emergency response issues.  The new CAER Code of Management Practices broadens the facility-community dialogue to cover the full range of safety, health and environmental issues.

Relationship to Guiding Principles

The Code helps achieve several of the Responsible Care® Guiding Principles:

Management Practices

A. Community Awareness and Outreach

Member facilities that manufacture, process, use, distribute or store hazardous materials shall have a community outreach program that includes:

For Employees:

  1.  An ongoing assessment of employee questions and concerns about the facility.
  2. Communications training for key facility and company personnel who communicate with employees and the public concerning safety, health, and environmental issues.
  3. Education of employees about the facility's emergency response plan and safety, health, and environmental programs.
  4. An ongoing dialogue with employees to respond to their questions and concerns and involve them in community outreach efforts.
  5. A regular evaluation of the effectiveness of the ongoing employee communications efforts.

For the Community:

  1. An ongoing assessment of community questions and concerns about the facility.
  2. An outreach program to educate responders, government officials, the media, other businesses and the community about the facility's emergency response program and risks to the community associated with the facility.
  3. A continuing dialogue with local citizens to respond to questions and concerns about safety, health, and the environment, and to address other issues of interest to the community.
  4. A policy of openness that provides convenient ways for interested persons to become familiar with the facility, its operations, and products, and its efforts to protect safety, health, and the environment.
  5. A regular evaluation of the effectiveness of the ongoing community communications efforts.

B. Emergency Response and Preparedness

  1. Member facilities that manufacture, process, use, distribute or store hazardous materials shall have an emergency response program that includes:
  2. An ongoing assessment of potential risks to employees and local communities resulting from accidents or other emergencies.
  3. A current, written facility emergency response plan which address, among other things, communications and the recovery needs of the community after an emergency.
  4. An ongoing training program for those employees who have response or communications responsibilities in the event of an emergency.
  5. Emergency exercises, at least annually, to test operability of the written emergency response plan.
  6. Communication of relevant and useful emergency response planning information to the Local Emergency Planning Committee.
  7. Facility tours for emergency responders to promote emergency preparedness and to provide current knowledge of facility operations.
  8. Coordination of the written facility emergency response plan with the comprehensive community emergency response plan and other facilities.  If no plan exists, the facility should initiate community efforts to create a plan.
  9. Participation in the community emergency response planning process to develop and periodically test the comprehensive community emergency response plan developed by the Local Emergency Planning Committee.
  10. Sharing of information and experience relating to emergency response planning, exercises, and the handling of incidents with other facilities in the community.

Member Self-Evaluation

 Each member company shall report annually to CMA, or its designated agent, the stage of implementation of each Management Practice in this Code.  The reports shall be on the member self-evaluation form attached as Exhibit A.

Pollution Prevention 

Purpose

This Code is designed to achieve ongoing reductions in the amount of all contaminants and pollutants released to the air, water, and land from member company facilities.  These reductions are intended to respond to public concerns with the existence of such releases, and to further increase the margin of safety for public health and the environment.

The Code is also designed to achieve ongoing reductions in the amount of wastes generated at facilities.  These reductions are intended to help relieve the burden on industry and society of managing such wastes in future years.

In implementing the Code, each company should strive for annual reductions, recognizing that production rates, new operations, and other factors may result in increases.  Despite these fluctuations, however, the goal is to establish a long-term, substantial downward trend in the amount of wastes generated and contaminants and pollutants released.  Quantitative reduction goals will be established for giving priority to those pollutants, contaminants and wastes of highest health and environmental concern.

This code also includes practices that address the broader waste management issues beyond source reduction and other waste and release reduction efforts.  Each member company must manage remaining wastes and releases in a manner that protects the environment and the health and safety of employees and the public.

This Code complements, and should be implemented in conjunction with current and future Codes of Management Practices.  Key terms are defined in the Glossary, which should be consulted for assistance in interpreting the provisions of this Code.

  Relationship to Guiding Principles

The Code helps achieve several of the Responsible Care® Guiding Principles:

Management Practices

Each member company shall have a pollution prevention program which shall include:

1. A clear commitment by senior management through policy, communications, and resources, to ongoing reductions at each of  the company’s facilities, in releases to the air, water, and land and in the generation of wastes.

2. A quantitative inventory at each facility of wastes generated and releases to the air, water, and land, measured or estimated at the point of generation or release.

3. Evaluation, sufficient to assist in establishing reduction priorities, of the potential impact of releases on the environment and the health and safety of employees and the public.

4. Education of, and dialogue with, employees and members of the public about the inventory, impact evaluation, and risks to the community.

5. Establishment of priorities, goals and plans for waste and release reduction, taking into account both community concerns and the potential health, safety, and environmental impacts as determined under Practices 3 and 4.

6. Ongoing reduction of wastes and releases, giving preference first to source reduction, second to recycle/reuse, and third to treatment.  These techniques may be used separately or in combination with one another.

7. Measurement of progress at each facility in reducing the generation of wastes and in reducing releases to the air, water, and land, by updating the quantitative inventory at least annually.

8. Ongoing dialogue with employees and members of the public regarding waste and release information, progress in achieving reductions, and future plans.  This dialogue should be at a personal, face-to-face level, where possible, and should emphasize listening to others and discussing their concerns and ideas.

9. Inclusion of waste and release prevention objectives in research and in design of new or modified facilities, processes, and products.

10. An ongoing program for promotion and support of waste and release reduction by others, which may, for example, include:

    a. Sharing of technical information and experience with customers and suppliers;

    b. Support of efforts to develop improved waste and release reduction techniques;

    c. Assisting in establishment of regional air monitoring networks;

    d. Participation in efforts to develop consensus approaches to the evaluation of environmental, health, and safety impacts of  releases;

    e. Providing educational workshops and training materials;

    f. Assisting local governments and others in establishment of waste reduction programs benefiting the general public.

11. Periodic evaluation of waste management practices associated with operations and equipment at each member company facility, taking into account community concerns and health, safety, and environmental impacts and implementation of ongoing improvements.

12. Implementation of a process for selecting, retaining, and reviewing contractors and toll manufacturers taking into account sound waste management practices that protect the environment and the health and safety of employees and the public.

13. Implementation of engineering and operating controls at each member company facility to improve prevention of and early detection of releases that may contaminate groundwater.

14. Implementation of an ongoing program for addressing past operating and waste management practices and for working with others to resolve identified problems at each active or inactive facility owned by a member company taking into account community concerns and health, safety, and environmental impacts.

 Industry Trend Data

To develop and maintain statistical industry trends, CMA will collect currently available data.  Each company shall report annually to CMA, or its designated agent, for each facility:

* Releases of substances as reported under SARA Section 313; and
* Wastes generated, as defined and reported in CMA’s annual  waste survey.

Member Self-Evaluation

Each member company shall report annually to CMA, or its designated agent, the stage of implementation of each management practice in this Code.  The reports shall be on the member self-evaluation form attached as Attachment A.

Glossary of Terms

As used in this Code, key terms are defined as set forth below.  Note that these definitions may be broader than regulatory definitions, and that adherence to this Code does not relieve a company of the obligation to meet Federal, state and local regulatory requirements.

Facility - A site used for chemical manufacturing, processing, refining, packaging, R&D, distribution or related commercial activity.

Recycle - A practice which regenerates or processes a material from a process to recover a useable product or material for reuse.

Release - Any emission, effluent, spill, discharge or disposal to the air, land, or water, of any pollutant or contaminant, whether routine or accidental, at or from a facility.  The term does not include shipment or distribution of chemical product, nor release to the environment as part of normal and intended use of a product by the consumer.

Reuse - A practice that reemploys a material from a process either as an ingredient in a process to make a product, or as an effective substitute for a commercial product in a particular function or application.

Source Reduction - A practice that reduces the amount of any release or waste generated at the source, including closed loop recycle and reuse before exit from a process.  The term includes, among other practices, equipment and technology modifications, process and procedures modifications, reformulation and redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training and inventory control.

Treatment - A practice, other than recycle or reuse, that alters the physical, chemical, or biological characteristics or the volume of a waste through a process or activity separate from the production of a commercial product or the provision of a service.

Waste - Any gas, liquid, or solid residual material at a facility, whether hazardous or non hazardous, that is not used further in the production of a commercial product or provision of a service and which itself is not a commercial product.
 

Process Safety 

Purpose

The Process Safety Code is designed to prevent fires, explosions and accidental chemical releases.  The Code is comprised of a series of management practices that reflect this goal, with the expectation of continuous performance improvement for each management practice.  The practices are based on the principle that facilities will be safe if they are designed according to sound engineering practices, built, operated and maintained properly and periodically reviewed for conformance.

Process safety is an interdisciplinary effort.  Consequently, the Code is divided into the following four elements:  management leadership, technology, facilities and personnel.  Each element is composed of Management Practices.  Individually, each Practice describes an activity or approach important to preventing fires, explosions and accidental chemical releases.  Collectively, the Practices encompass process safety from the design stage through operation, maintenance and training.  The scope of this Code includes manufacturing, processing, handling and on-site storage of chemicals.  This Code must be implemented with full recognition of the community’s interest, expectations and participation in achieving safe operations.

The process safety management program in each facility is complemented by workplace health and safety programs, as well as waste and release reduction programs which address and minimize releases and waste generation.  These three programs, and others, will help assure that CMA member facilities are operated in a manner that protects the environment and the health and safety of personnel and the public.
 

Relationship to Guiding Principles

The Code helps achieve several of the Responsible Care®  Guiding Principles:

Management Practices

Each member company shall have an ongoing process safety program that includes:

Management Leadership
1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance.

2. Clear accountability for performance against specific goals for continuous improvement.

3. Measurement of performance, audits for compliance and implementation of corrective actions.

4. Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in a fire, explosion or accidental chemical release.

5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry, government and the community.

6. Use of the Community Awareness and Emergency Response (CAER) process to assure public comments and concerns are considered in design and implementation of the facility’s process safety systems.

Technology
7. Current, complete documentation of process design and operating parameters and procedures.

8. Current, complete documentation of information relating to the hazards of materials and process technology.

9. Periodic assessment and documentation of process hazards, and implementation of actions to minimize risks associated with chemical operations, including the possibility of human error.

10. Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility.

Facilities
11. Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment, and employees.

12. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards.

13. Safety reviews on all new and modified facilities during design and prior to start-up.

14. Documented maintenance and inspection programs that ensure facility integrity.

15. Sufficient layers of protection through technology, facilities and employees to prevent escalation from a single failure to a catastrophic event.

16. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions.

Personnel
17. Identification of the skills and knowledge necessary to perform each job.

18. Establishment of procedures and work practices for safe operating and maintenance activities.

19. Training for all employees to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job.

20. Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter.

21. Programs designed to assure that employees in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse.

22. Provisions that contractors either have programs for their own employees consistent with applicable sections of this Code or be included in the member company’s program, or some combination of the two.

 Glossary

This Code uses key terms in a context that may be broader than their associated regulatory definitions.  However, adherence to this Code does not relieve a company of the obligation to meet Federal, state and local regulatory requirements.

Process Safety -  The application of management and engineering principles to prevent fires, explosions and accidental chemical releases at chemical process facilities.

Sound Engineering Practice -  The application of mandatory codes and standards supplemented by the use of voluntary codes, standards and guidelines, tempered by professional judgment.

Safety Critical Jobs -  Jobs, activities and tasks, if improperly performed, that have the potential to significantly increase the risk of a fire, explosion or accidental chemical release.

Accidental Chemical Release -  Unplanned, sudden releases of chemicals from manufacturing, processing, handling and on-site storage facilities to the air, water or land.  It does not include permitted or other releases.
 

Distribution 

Purpose

The purpose of the Distribution Code of Management Practices is to reduce the risk of harm posed by the distribution of chemicals to the general public; to carrier, distributor, contractor and chemical industry employees; and to the environment.  Adherence to  the code will lead to continually safer chemical distribution and help member companies to:

The code will also promote improvements in:

The Distribution Code of Management Practices applies to all modes of transportation (highway, rail, marine, air and pipeline) and to the shipment of all chemicals, including chemical waste.  The code also applies to distribution activities (storage, handling, transfer and repackaging) while chemicals are in transit between member companies and their suppliers and customers.  The implementation of a number of practices of the code will vary according to the characteristics of the chemical being distributed, the mode of transportation and the type of distribution activity involved.

Relationship to Guiding Principles

This code helps achieve several Responsible Care® Guiding Principles:

Management Practices

Each member company shall have an ongoing chemical distribution safety program that includes senior management commitment through policy, communications and resources to improvements in chemical distribution safety.  The program should include the following elements:

1. Risk Management

1.1 Regular evaluations of chemical distribution risks which consider the hazards of the material, the likelihood of accidents/incidents and the potential for human and environmental exposure from release of the material over the route of transport.

1.2 Implementation of chemical distribution risk reduction measures that are appropriate to the risk level.

1.3 Internal reporting and investigation of chemical distribution accidents/incidents, and implementation of preventive measures.

2. Compliance Review and Training

2.1 A process for monitoring changes and interpretations of new and existing regulations and industry standards for their applicability to the company’s chemical distribution activities, and for implementing those regulations and standards.

2.2 Training for all affected company employees in the proper implementation of applicable regulations and company requirements.

2.3 A program for providing guidance and information to carriers, distributors and contractors who perform distribution activities for the company on the company’s training and compliance requirements for the activities.

2.4 Regular reviews of company employee, carrier, distributor and contractor compliance with applicable regulations and company requirements.

3. Carrier Safety

3.1 A process for qualifying carriers of all modes and types (common, contract, private and customer controlled) that transport chemicals to and from company facilities that emphasizes carrier safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance.
 
3.2 Feedback to carriers on their safety performance and suggestions for improvement.

4. Handling and Storage

4.1 Documented procedures for the selection and use of containers that are appropriate for the chemical being shipped, in compliance with testing and certification requirements, and free of leaks and visible defects.

4.2 Documented procedures for loading chemicals at company facilities that will reduce emissions to the environment, protect personnel and provide securement of the lading during transit.

4.3 Documented procedures for unloading chemicals at the company’s facilities that will reduce emissions to the environment, protect personnel, and provide for safe unloading into proper storage facilities.

4.4 Defined criteria for the cleaning and return of tank cars, tank trucks, marine vessels, and returnable/refillable bulk and semi-bulk containers, and for the proper disposal of cleaning residues.

4.5 A program for providing guidance and information to customers, distributors, and other receivers on proper procedures for unloading and storing the company’s chemicals.

4.6 A process for selecting distributors and other facilities that store or handle the company’s chemicals in transit that emphasizes safety fitness and regulatory compliance and includes regular reviews of their performance and compliance.

4.7 Feedback to distributors and operators of other facilities that store or handle chemicals in transit on their safety performance and suggestions for improvement.

 5. Emergency Preparedness

5.1 A process for responding to chemical distribution accident/incidents involving the company’s chemicals.

5.2 Documented procedures for making information about the company’s chemicals in distribution available to response agencies.

5.3 A program for making facilities and/or training materials available to emergency response agencies.

5.4 Dialogue with state and local emergency planning organiza-tions on the distribution and hazards of the company’s chemicals to improve community preparedness to respond to chemical distribution emergencies.

5.5 Dialogue with the public on their concerns about chemical distribution safety, actions taken by the industry and the company to improve the safety of chemical distribution, and the effectiveness of emergency preparedness and emergency response assistance.

Member Self Evaluation

Member companies shall report annually the stage of implementation of each management practice in this code to an agent designated by the Chemical Manufacturers Association.
 

Relationship to Other Codes of Management Practices

This Code complements, and should be implemented in conjunction with, current and future Codes of Management Practices.
 

TRANSCAER®
 
Do you know if hazardous materials are passing by your community?  Does your community know what to do in the case of a transportation incident?  Are you prepared??

TRANSCAER® (Transportation Community Awareness Emergency Response) is a national outreach program sponsored by the manufacturing, distributor and transportation industries that combines the resources of all three industries to help communities prepare for a possible transportation incident.  TRANSCAER® focuses on communities that have a major transportation route, but are not located near a chemical facility.

TRANSCAER® emphasizes a partnership between industry and community by providing an opportunity for the two to come together and discuss the risks involved with the transportation of hazardous materials.  TRANSCAER® provides communities access to industry representatives who can help them prepare and plan for a possible transportation incident.

Become involved with TRANSCAER®!  If you are a community member or industry representative, please become involved.

Employee Health and Safety 

Purpose

The goal of the Employee Health and Safety Code of Management Practices is to protect and promote the health and safety of people working at or visiting member company work sites.

To achieve this goal, the Code provides Management Practices designed to continuously improve work site health and safety.  These practices provide a multidisciplinary means to identify and assess hazards, prevent unsafe acts and conditions, maintain and improve employee health, and foster communication on health and safety issues.

Implementation of the Employee Health and Safety Code, together with other Codes of Management Practices, can enable member companies to operate in a manner that further protects and promotes the health and safety of employees, contractors, and the public, and protects the environment.
 

Relationship to Guiding Principles

Implementation of the Code helps achieve several of the Responsible Care® Guiding Principles:

Management Practices

Each member company shall have an ongoing occupational health and safety program that includes:

Program Management

1. Commitment by all levels of management to protecting and promoting the health and safety of people working at or visiting member company work sites, through: published policies; accountability for implementation; and provision of sufficient resources, including qualified health and safety personnel.

2. Opportunities for employees to participate in developing, implementing, and reviewing health and safety programs.

3. Provisions, including selection criteria, to confirm that on-site contractors’ programs are consistent with applicable Management Practices of this Code.

4. Written, up-to-date health and safety programs and procedures appropriate to the facility.

5. Means to verify that health and safety programs and procedures are effective and that actual practices are consistent with these programs and procedures.

6. Systems for maintaining records and analyzing data to evaluate health and safety performance, determine trends, and identify areas for improvement.

Identification and Evaluation

7. Methods to identify and evaluate potential health and safety hazards in planned or existing facilities, including facilities to be modified.

8. Exposure assessments and safety analyses to evaluate health and safety hazards to employees from processes; equipment; potentially hazardous chemical, physical, or biological agents; or other work site conditions.

9. Health assessments to determine employee medical fitness for specific job tasks.

10. Employee occupational medical surveillance programs tailored to work site hazards.

 Prevention and Control

11. Mechanisms for reviewing the design and modification of facilities and job tasks, taking into account the following hierarchy of controls:  inherent safe design, material substitution, engineering controls, administrative controls, and personal protective equipment.

12. Systems to verify that health and safety equipment is properly selected, maintained, and used.

13. Preventive maintenance and housekeeping programs to maintain the safety of  facilities, tools, and equipment.

14. Timely investigation of work site illnesses, injuries, and incidents; corrective actions to prevent recurrence; and evaluation of the effectiveness of corrective actions taken.

15. Security procedures and systems to control entry and exit of personnel and materials at the work site and restricted areas.

16. Provisions for emergency medical assistance for people at work sites.

Communications and Training

17. Communication of health and safety information that is relevant to specific job tasks and the work site.

18. Health and safety training programs, including documentation of these programs, and methods to evaluate the effectiveness of both training and communications activities.

Industry Trend Data

To identify industry trends, each company shall report to CMA, or its designated agent, occupational injuries and illnesses, as specified in CMA’s Occupational Injury and Illness Reporting Program.
 

Relationship to Other Codes of Management Practices

This Code complements, and should be implemented in conjunction with, current and future Codes of Management Practices, especially those elements of the CAER Code involving emergency response, the Process Safety Code involving training of employees in their job functions, and the Product Stewardship Code involving health, safety, and environmental information, and employee education and product use feedback.
 

Member Self-Evaluation

Each member company shall report annually to CMA, or its designated agent, the implementation category attained for each Management Practice in this Code.  The reports should be submitted on the member self-evaluation form provided.

The Responsible Care®   Employee Health & Safety Code of Management Practices was approved by CMA's Board of Directors on January 14, 1992
 

Product Stewardship 

Purpose and Scope

The purpose of the Product Stewardship Code of Management Practices is to make health, safety and environmental protection an integral part of designing, manufacturing, marketing, distributing, using, recycling and disposing of our products.  The Code provides guidance as well as a means to measure continuous improvement in the practice of product stewardship.

The scope of the Code covers all stages of a product's life.  Successful implementation is a shared responsibility.  Everyone involved with the product has responsibilities to address society's interest in a healthy environment and in products that can be used safely.  All employers are responsible for providing a safe workplace, and all who use and handle products must follow safe and environmentally sound practices.

The Code recognizes that each company must exercise independent judgment and discretion to successfully apply the Code to its products, customers and business.
 

Relationship to Guiding Principles

Implementation of the Code promotes achievement of several of the Responsible Care® Guiding Principles:

Management Practices

Each company shall have an ongoing product stewardship process that:
 

Management Leadership and Commitment
 

1. LEADERSHIP:  Demonstrates senior management leadership through written policy, active participation and communication.

2. ACCOUNTABILITY and PERFORMANCE MEASUREMENT:  Establishes goals and responsibilities for implementing product stewardship throughout the organization.  Measures performance against these goals.

3. RESOURCES:  Commits resources necessary to implement and maintain product stewardship practices.

Information and Characterization

4. HEALTH, SAFETY and ENVIRONMENTAL INFORMATION:  Establishes and maintains information on health, safety, and environmental hazards and reasonably foreseeable exposures from new and existing products.

5. PRODUCT RISK CHARACTERIZATION:  Characterizes new and existing products with respect to their risk using information about health, safety, and environmental hazards and reasonably foreseeable exposures.  Establishes a system that initiates re-evaluation.

 Risk Management

 6. RISK-MANAGEMENT SYSTEM:  Establishes a system to identify, document, and implement health, safety and environmental risk-management actions appropriate to the product risk.

 7. PRODUCT and PROCESS DESIGN and IMPROVEMENT:  Establishes and maintains a system that makes health, safety and environmental impacts—including the use of energy and natural resources—key considerations in designing, developing and improving products and processes.

8. EMPLOYEE EDUCATION and PRODUCT USE FEEDBACK:  Educates and trains employees, based on job function, on the proper handling, recycling, use, and disposal of products and known product uses.  Implements a system that encourages employees to feed back information on new uses, identified misuses or adverse effects for use in product risk characterization.

9. CONTRACT MANUFACTURERS:  Selects contract manufacturers who employ appropriate practices for health, safety and environmental protection for the operations under contract, or works with contract manufacturers to help them implement such practices.  Provides information and guidance appropriate to the product and process risk to foster proper handling, use, recycling and disposal.  Periodically reviews performance of contract manufacturers.

10. SUPPLIERS:  Requires suppliers to provide appropriate health, safety and environmental information and guidance on their products.  Factors adherence to sound health, safety, and environmental principles, such as those contained in Responsible Care® into procurement decisions.

11. DISTRIBUTORS:  Provides health, safety and environmental information to distributors.  Commensurate with product risk, selects, works with and periodically reviews distributors to foster proper use, handling, recycling, disposal and transmittal  of appropriate information to downstream users.  When a company identifies improper practices involving a product, it will work with the distributor to improve those practices.  If, in the company’s independent judgment, improvement is not evident, then the company should take further measures -- up to and including termination of the business relationship.  This Management Practice should be implemented in conjunction with the Distribution Code of Management Practices.

12. CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS:  Provides health, safety and environmental information to direct product receivers. Commensurate with product risk, works with them to foster proper use, handling, recycling, disposal, and transmittal of appropriate information to downstream users.  When a company identifies improper practices involving a product, it will work with the product receiver to improve those practices.  If, in the company’s independent judgment, improvement is not evident, then the company should take further measures -- up to and including termination of product sale.

Relationship to Other Codes of Management Practices

This code complements, and should be implemented in conjunction with, current and future Codes of Management Practices.