ENVIRONMENTAL

PROTECTION CODE
Document Number : GPCA-RC-C07
Re-issue Date: January 01, 2018
Revision Number: 01
Prepared / Reviewed by: RC Codes Subcommittee
Ownership: Responsible Care® GPCA
Approval: Dr. Abdul Wahab Al-Sadoun

Acknowledgements

Reviewed and Revised by

Responsible Care Codes Subcommittee

Name Title Company

Nassir Al Harbi Team Leader ARAMCO

Hani Al-Subhi Member SABIC

Ahmad Habalreh Member YANSAB

Philip Yee Member SADARA

Kashif Rasheed Sr. RC Specialist GPCA

Originally Developed by
Environmental Protection Code Task Force 07
Original Issue: June 15, 2011

Saeed Algarni TF Leader SAHARA

Naved Khan Member QAPCO

Sudhir Sivarajan Member BOUROUGE

Adil Majid Member NATPET

Abduarasheed Jafar Member SABIC

Table of Contents

Descriptions Page No.

Chapter One 4
Introduction 4
Codes of Management Practices Links to RC 14001:2015 Standard 6
Chapter Two 7
Management Practices (MP), Guidance, Suggested Activities / Examples and 7
Self-assessment
Leadership Planning and Prioritization 7
EP-1 Environmental Policy 7
EP-2 Establishing Reduction Targets 8
EP-3 Environmental Impact 9
EP-4 Environmental Planning 10
EP-5 Waste Management Hierarchy 11
Training, Communication and Community Engagement 13
EP-6 Training 13
EP-7 Communication 14
EP-8 Environmental Awareness 15
Implementation, Assessment and Improvement 17
EP-9 Monitoring and Reporting 17
EP-10 Evaluation and Target Setting 17
EP-11 Environmental Review 18
EP-12 Contractor Competency 19
EP-13 Groundwater Protection 20
EP-14 Continuous Improvement 21
Chapter Three 23
References 23
Gulf Petrochemicals & Chemicals Association

CHAPTER ONE
Introduction

In December 2009, the Gulf Petrochemicals and Chemicals Association (GPCA) Board of Directors
formally adopted the Chemical Industry’s initiative called ‘Responsible Care®’.

Responsible Care® was created in 1984 by the Canadian Chemical Producers’ Association, with the
clear intent of establishing the following goals:

• Improved chemical processes.

• Enhanced practices and procedures.
• Sustainable use of resources and energy intensity.
• Reduction of every kind of waste, incident, and discharge
• Reliable communication and dialogue.
• Heightened public scrutiny and input.

Responsible Care® has become an obligation of membership in GPCA Member Companies. A

central idea behind Responsible Care® is the need to adopt philosophy of continuous improvement.
It is not a program that provides a checklist of activities for member companies to implement. It
will be improved continually in light of new information, new technology, new expectations, and a
constant reassessment of performance and objectives. Responsible Care® is a license to operate.

Management Codes
Responsible Care® is underpinned by GPCA through the implementation of a number of
Management Codes as indicated below:

Management Code Document Number

Community Awareness and Emergency Response (CAER) GPCA-RC-C01

Distribution GPCA-RC-C02

Product Stewardship GPCA-RC-C03

Security GPCA-RC-C04

Health & Safety GPCA-RC-C05

Process Safety GPCA-RC-C06

Environmental Protection GPCA-RC-C07

Each of the above Codes includes expectations, termed Management Practices. The Management
Practices provide specific technical requirements and guidance for Companies to fulfil their
responsibilities in terms of Responsible Care® and can be used as a self-assessment tool.
 Environmental Protection Code | 5

Objective – Environmental Protection Code

This Code is designed to achieve further reductions in the amount of all contaminants and pollutants
released to the air, water, and land from GPCA 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 environmental protection. Additionally, proper utilization
of natural resources should be practiced.

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. Reduction in intensity
targets should be established 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 GPCA member company
must manage remaining wastes and releases in a manner that minimizes the impact on the
environment, health and safety of employees and the public.

This Code is divided into the following three elements:

1. Leadership, Planning and Prioritization.

2. Training, Communication and Community Engagement.
3. Implementation, Assessment and Improvement.

Each element is composed of Management Practices as indicated in Table 1 – Environmental

Protection Management Practices. Individually, each Practice describes an activity or approach to
implementing the requirements of this Code.

Codes of Management Practices Links to RC 14001:2015 Standard

The implementation of the Environmental Protection Code will help in fulfilling the requirements of
the Responsible Care® management system specification RC 14001. Notably, the implementation
will help in closing gaps related to environmental protection requirements of the specification,
particularly those requiring the reduction of contaminants and pollutants released from GPCA
member company facilities.
Gulf Petrochemicals & Chemicals Association

Environmental Protection Management Practices

RC 14001 Responsible Care®

EP – 10

EP – 11

EP – 12

EP – 13

EP – 14
EP – 1

EP – 2

EP – 3

EP – 4

EP – 5

EP – 6

EP – 7

EP – 8

EP – 9
Elements

4.1 Understanding the organization and

X
its context
4.2 Understanding the needs and
X X X X X X X
expectations of interested parties
4.3 Determining the scope of the EHS&S
management system
4.4 EHS&S management system X X X X
5.1 Leadership and commitment X
5.2 Policy X
5.3 Organizational roles, responsibilities
X

Training, Communication and Community Engagement

and authorities

Implementation, Assessment and Improvement

6.1 Actions to address risks and
X X X X X X
Leadership, Planning and Prioritisation

opportunities
6.1.2 EHS&S aspects X X X X
6.1.3 Compliance obligations (Legal & Other
X X X
Requirements)
6.2 EHS&S objectives and planning to
X X X X X X X
achieve them
6.2.2 Planning actions to achieve EHS&S
X X X X X X
objectives
7.1 Resources X
7.2 Competence X
7.3 Awareness X X
7.4 Communication X X X X X X X
7.5 Documented Information X X X X X
8.1 Operational planning and control X X X X X X X X X
8.2 Emergency preparedness and response X X
9.1 Monitoring, measurement, analysis
X X X X X X X X X
and evaluation
9.1.2 Evaluation of compliance
9.2 Internal audit
9.3 Management Review X X
10.2 Nonconformity and corrective action
10.3 Continual Improvement X X X X X

Table 1 – Environmental Protection Management Practices

These management practices should be included in the member company’s existing environmental
management systems and programs which address Environmental Protection related requirements.
Moreover, these practices should be incorporated into the existing management systems and
programs in such a way to fulfill the requirements of the latest edition of RC 14001.
 Environmental Protection Code | 7

CHAPTER TWO
Management Practices, Guidance, Suggested
Activities / Examples and Self-assessment

Leadership, Planning and Prioritisation

EP-1: Environmental Policy

A clear commitment by senior management through policy, communications, and resources,
to comply with relevant environmental laws and regulations, and other requirements to achieve
continual improvement. The commitment includes minimization of pollution through ongoing
reductions at each of the GPCA company facilities, in releases to the air, water, land, waste
reduction and optimize the usage of natural resources.

1.0 Guidance
A well-defined, comprehensive policy is the driver for implementing and improving an organization’s
environmental management system to maintain and improve its environmental performance. The
policy should reflect the commitment of top management to comply with applicable legal and other
requirements, to prevent pollution and continual improve. The policy should form the basis upon
which the organization sets its objectives and targets. The policy should be communicated to all
stakeholders.

1.1 Suggested Activities / Examples
Example No. 1
Typical examples for this management practice are Company EHSS or Environmental Protection
Policy signed by top management. Policies must have clear statements of recognition and
compliance with relevant environmental laws and regulations. Environmental goals are established
for the company and expressed to all stakeholders. Integrate corporate goals into facility and
department goals, or vice-versa. Environmental responsibilities are assigned to personnel at all
levels within the Company.

Example No. 2
Each company must tailor its own program of communications demonstrating company commitment
to policy objectives and goals. Policies should be published and shared with all stakeholders as
applicable. Communication can be through websites, media, mailings or discussions conducted
through meetings. Employees must know and understand what top management expects
in environmental performance. Each Business unit should communicate that environmental
expectations are high and are periodically stated by each Facility Manager. Senior business unit
management should periodically visit facilities and communicate to employees/contractors their
commitment to environmental performance.

Each company should ensure that there is a plan for implementation of the Environmental
Protection Code adopted by Senior Management with goals defined for achievement, and
effectively communicated to all employees.
Gulf Petrochemicals & Chemicals Association

Example No. 3
Companies must assign adequate resources to implement the policies and goals.
Training and competency enhancement on environmental issues is required at facilities for all
employees/contractors and evidence of environmental training, competency should be available.

There should be environmental knowledge on the board of directors and environmental training is
required for line managers.

Example No. 4
Environmental planning is integrated with business planning so that acquisitions, divestitures,
research and development (R&D) initiatives, capital projects, new products and future actions with
environmental consequences can be appropriately addressed.

Environmental performance and reporting is given as much importance as production, quality and
financial performance reporting. Environmental reporting is included at business meetings.

Procedures should be in place for environmental incident reporting, including their causes and
corrective actions.

Environmental audits are required at all facilities on a periodic basis to achieve continual
improvement.

1.2 Self-assessment
• Is there a published and visibly communicated company policy for the environmental protection?
• Does Senior Management regularly state the importance of the environmental protection in
employee/contractors meetings or forums?
• Are there defined accountabilities and adequate resources at various levels in the company for
meeting the environment programs?
• Are annual environmental targets established to address the company’s environmental
concerns?

EP-2: Establishing Reduction Targets

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

1.0 Guidance
This Management Practice deals with setting priorities and goals, developing plans, and
communicating them. When establishing priorities, the organization should consider goals,
plans, the potential health, safety, and environmental impacts as well as community concerns.
Understanding community concerns involves ongoing dialogue with employees and members of
the community.

1.1 Suggested Activities / Examples

Example No. 1
Facilities have a list of environmental improvement projects prioritized based on stakeholder’s
 Environmental Protection Code | 9

inputs. Resource needs are identified. Discharge and release reduction goals are part of the
facility’s business plans or performance balance score card and are incorporated into budget and
planning cycle.

Example No. 2
Activities to comply with this Management Practice include the identification of resources and
specialists needed to assess facility processes. Processes should be analyzed to identify reduction
opportunities, recycle/reuse, or treatment of wastes and releases.

Results from environmental impact assessments and stakeholder’s surveys should be prioritized
based on its significance.

The mitigation plan required to reduce the environmental impacts should be prioritized in
economically sound manner. Implementation schedule with resources required should be
presented to management for endorsement.

1.2 Self-assessment
• Does the company have a documented self-assessment tool of all environmental legal & other
requirements?
• Does the company have a prioritized list of environmental programs to achieve continual
improvements?
• Are these goals monitored and tracked regularly (KPI’s)?

EP-3: Environmental Impact

Evaluation of the potential impact of releases on the environment from past, current, future and
emergency activities on the environment, health and safety of employees and the public.

1.0 Guidance
This Management Practice calls for each company to perform an evaluation of the potential impacts
on human health and the environment of the releases and discharges identified in Management
Practice 2. This analysis will vary in complexity from facility to facility.

The purpose of evaluating impacts is threefold. First, it can serve as an aid to the company in
prioritizing environmental projects. Second, it can aid company representatives when discussing
the facility’s potential impacts and environmental programs with neighbors. Third, it can provide a
basis for communicating the environmental programs and its priorities to employees.

Each facility is responsible for developing priorities for controlling environmental releases. Each
facility should evaluate specific conditions including evaluation of proximity to population and
existence of sensitive receptors.

1.1 Suggested Activities / Examples

Example No. 1
The organization develops and implements procedures to identify its environmental aspects and
impacts. Typical activity is evaluation of the impact on the environment due to atmospheric releases
to air, water body and releases to land. The facility evaluates the specific spill control measures
Gulf Petrochemicals & Chemicals Association

and waste disposal practices and establishes priorities, taking into account volumes and toxicity.
Possible considerations for evaluation are:
• Regulations.
• Odors and visible releases.
• Employee and public sensitivities.
• Population distance and density.
• Volume and toxicity.
• Release pathways.
• Modelling and monitoring.

Example No. 2
Each facility needs to develop and implement an Emergency Response Plan that addresses credible
environmental incidents.

1.2 Self-assessment
• Does the company have a system in place to report and track environmental incidents?
• Are system is in place to monitor and control regulated environmental releases and discharges?
• Does the company have control measures to reduce the impact of environmental releases and
discharges?
• Does the company have an emergency plan for environmental incidents?

EP-4: Environmental Planning

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

1.0 Guidance
Consider integrating the concept of environmental protection throughout the lifecycle assessment
of products starting from the research and development, engineering design of new or modified
facilities, manufacturing, storage, distribution, usage and disposal. Internal integration of
comprehensive environmental programs throughout the lifecycle of the product can help reduce
discharges and releases.

While integrating environmental programs into strategic planning, product development and
lifecycle, consider issues such as:
• Compliance to regulations.
• Quantity of waste.
• Cost of waste management.
• Environmental and safety liability.
• Potential for minimization and utilization.
• Potential recovery of valuable by-products.
• Emerging process technologies that may improve performance.
• Finding new markets, etc.

Integration of environmental management practices throughout the cycle of products could benefit
the quality of products, minimize material loss, improve health and environment performance,
stakeholder confidence and result in higher returns.
 Environmental Protection Code | 11

1.1 Suggested Activities / Examples

Example No. 1
Conduct workshops / awareness sessions, and have dialogue with operations staff, process and
design engineers and environmental specialists who may help to develop ways to reduce the
generation of wastes and/or releases.

Example No. 2
Evaluate technological options and new markets for recycle / reuse / reclaim of by-products and
wastes to minimize the material loss and reduce waste disposal costs.

Example No. 3
Conduct periodic reviews based on self and internal evaluation to track and measure the actual
performance of implemented environment programs, ensuring the learning’s are feedback for
continuous improvement.

1.2 Self-assessment
• Are environmental implications considered at an appropriate stage of a new facility, process or
product?
• Are the identified aspects and impacts formally assessed and where applicable followed
through during future development phases?
• Is there evidence of the outcome of this assessment resulting in alternative solutions being
selected?

EP-5: Waste Management Hierarchy

Ongoing reduction of wastes and releases, giving preference to:
1. Reduce the source.
2. Recycle / Reuse / Recover.
3. Treatment and disposal

These techniques may be used separately or in combination with one another.

1.0 Guidance
Being a Responsible Care® organization, the management is focused on the ongoing waste and
releases reduction programs by adopting the ‘4Rs’ principle to sustain environmental performance
and ensure continuous improvement. The ‘4Rs’ programs followed in the order of preference are:
1. Reduce.
Minimizing the wastes and releases at source.
2. Reuse.
Recovered material used by the outside customers.
3. Recycle.
Utilizing the waste and releases within the process.
4. Recover.
Partially utilizing the waste or byproduct in the process.

Several techniques can be adopted that will help in reducing the waste and releases, which include:
Gulf Petrochemicals & Chemicals Association

• Process modifications.
Evaluating the entire manufacturing process and modifying the process parameters to obtain
high yields and reduced wastes and releases.

• Materials substitution
Substitution of process chemicals, as appropriate with high efficiency and high selectivity
materials and modification of equipment to reduce generation of wastes and releases.

• Housekeeping
Improved housekeeping including material stock control, segregation of wastes, preventive
maintenance, spills and leak prevention to assist in improved material utilization and reduced
disposable wastes.

• Recycle, reuse and recover

Recycling and reuse of waste and releases to generate valuable by-products and reduce
material loss.

Pollution reduction programs will help in managing environmental responsibilities, compliance with
the applicable local / international legislation, improved material utilization and reduced wastes and
releases. The engineering and technical experts of the organization can contribute by proposing
new materials, equipment modification, recycle / reuse of waste.

1.1 Suggested Activities / Examples

Example No. 1
Conduct meetings, discussions, and have dialogue with engineering and technical experts to review
the sources / causes of generating waste and releases and the potential solutions to minimize and
recycle / reuse/recover wastes and releases.

Example No. 2
Re-evaluating the entire operations and operating parameters, and modification / fine tuning of
these parameters could result in effective reduction of waste and releases. For example, adjusting
the combustion temperatures and excess air supply could result in reduced carbon monoxide (CO)
and nitrous oxide (NOx) emissions. Regular monitoring and preventive maintenance of steam traps
and pressure relief valves could result in energy savings, water conservation and minimized flaring.

Example No. 3
Material substitution, such as the use of high efficiency / selectivity catalysts can give higher
productivity and reduced waste and releases. Equipment modifications such as combustion zone
modifications and use of low NOx burners could help in reducing air emissions.

Example No. 4
Good operating practices and housekeeping is a basic environmental practice. An efficient material
inventory system is supported by acquiring only the material that is needed, combined with storing
materials in labelled containers with clearly marked expiry dates ensures the use of the material
within the shelf life thereby reducing the generation of wastes from unused materials.
 Environmental Protection Code | 13

Example No. 5
Segregate different types of wastes to increase opportunities for waste recycling, recover, reuse
and reduction of disposable wastes. Evaluate technological options for recycling and reuse of
wastes and releases. Spent catalyst regeneration, waste oil reuse as fuel, use of process gases
and hydrocarbon waste for energy recovery, lead recovery from used batteries, reuse of treated
wastewater and recovered condensate, are some of the potential reuse / recycle/recover areas that
help reduce waste and releases. The use of secondary containments, dip trays, splash guards are
other examples to contain and recover material during spills and leaks.

Example No. 6
Sharing of waste and release reduction programs with customers, suppliers and business partners
to help reduce wastes and releases throughout the product cycle.

1.2 Self-assessment
• Is there an appropriate accountable person(s) appointed for the environmental reduction plan?
• Is there data demonstrating the progression of ongoing reduction for the prioritized wastes and
releases?
• Does the plan show preference of reduction hierarchy? Source > recycle / reuse/recover >
treatment.

Training, Communication and Community Engagement

EP-6: Training
Education of, and dialogue with, stakeholders, impact evaluation, and risks to the community.

1.0 Guidance
Effective education of workers (employees/contactors) is the key for the environment protection
and shall not be limited to newsletters, mails, posters, bulletins, etc. Workers technical
empowerment programs should involve interactive hands-on process, classroom training, higher
education programs, workshops, meetings, etc. The education efforts shall provide an opportunity
for all organization levels to function effectively in a team.

Nearby communities are also important stakeholders in the successful operation of the business.
It is very important to win the confidence of the community and to convince them about the
environmental risks from the organization’s activities, and the plans and programs being implemented
to prevent pollution and make the environment safe. Environmental awareness sessions tailored
specifically to the community at pre-arranged meetings are means of educating the community. The
effective education of workers and community awareness could be implemented by establishing a
training needs assessment and awareness requirements based on the risk assessment studies. It
is important to establish a mechanism to receive and act on workers and public feedback relating
to environmental practices to enhance the effectiveness of education and community awareness.

1.1 Suggested Activities / Examples

Example No. 1
Identify the activities that have potential significant environmental risks. Develop standard operating
procedures (SOPs) and provide hands on training to the workers associated with these activities
and brief them on the impacts of deviating from the SOPs. Conduct regular meetings, training or
Gulf Petrochemicals & Chemicals Association

workshops with workers to refresh their knowledge and track concerns.

Example No. 2
The use of audio-visual aids used during a presentation will drive and focus dialogue, particularly
when carrying out community information awareness sessions.

Example No. 3
Conduct surveys, interviews, tests to measure the effectiveness of education, awareness and dialogue,
and the perception of employees and community about the organization’s environment efforts.

1.2 Self-assessment
• Is there provision of environmental awareness and refresher training for stakeholders?
• Is there a schedule of awareness sessions targeting the local community associated with a
company facility(s)

EP-7: Communication
Ongoing dialogue with workers and members of the public regarding discharges 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.

1.0 Guidance
Workers are the assets of the organization and play a key role in the environment. Discussing
the environment with workers is challenging and requires continual enhancement of the their
technical knowledge in developing and evaluating the emissions inventories, estimating the release
/ spill quantities, assessing the impacts, developing and implementing plans to achieve emission
reductions, and risks mitigations from the releases.

Nearby communities are also important stakeholders in the successful operation of the business.
It is very important to win the confidence of the community and to convince them about the
environmental risks from the organization’s activities, the plans and programs being implemented
to prevent pollution and make the environment safe.

Identify the spokesperson(s) (internal and external) for the facility and the effective methodologies
to facilitate effective education and dialogue.

1.1 Suggested Activities / Examples

Example No. 1
Prepare newsletters, brochures, hand-outs, audio-visual aids and presentations to convey
environment information and programs. Simplify and provide the information to be appropriate to
the competency of the workers and in a language they can easily absorb.

Example No. 2
Emissions release and discharge generation data provides an accepted method for highlighting ongoing
results associated with the environment protections programs. The data reported should be provided
in a language that can easily understood and it should combined with local regulatory standards.
 Environmental Protection Code | 15

Example No. 3
The community is not knowledgeable about the organizations activities, releases, discharges, and
chemicals handled. Therefore the dialogue should begin with a brief introduction about facility
operations and environmental release obligations. This introduction can be supported by brochures
and other appropriate hand-out materials. After the introduction, the audience will have a basic
understanding of the organization and will be ready to learn about a facility’s environmental efforts.
For this portion of the presentation, data should be updated and presented annually. The format
should be simple, clear and easy to revise from year to year. Histograms (bar charts) may be the
easiest way to show comparisons and differences. An improving trend in emissions from year to
year is an impressive and effective message about reduction efforts.

Example No. 4
Consider dialogue about the way in which the facility is making progress toward reducing discharges
and releases. Declare the ongoing costs for environment improvement programs and activities.
Highlight voluntary efforts and describe specific reduction programs, or innovative strategies that
are underway or planned for implementation.

1.2 Self-assessment
• Is regular dialogue carried out with stakeholders on environmental issues?
• Is there evidence to demonstrate that feedback received during dialogue is utilized when
developing future environment improvement plans?

EP-8: Environmental Awareness

An ongoing program for promotion and support of waste and release reduction by others which
may include:
1. Sharing of technical information and experience with customers and suppliers.
2. Support of efforts to develop improved waste and release reduction techniques.
3. Assisting in establishment of regional ambient air monitoring networks.
4. Participation in efforts to develop consensus approaches to the evaluation of environmental,
health and safety impacts of releases.
5. Providing educational workshops and training material.
6. Assisting local governments and others establishing waste reduction programs benefiting the
general public.

1.0 Guidance
The implementation of integrated environmental programs helps in managing environmental
responsibilities and acts as a means to guide business organization compliance with applicable
local and/or international legislation.

Being a responsible member of the society and a Responsible Care® organization, promote
Responsible Care® by sharing internal integrated environmental programs and experiences and
offering assistance to others involved throughout the product lifecycle. The Environmental Protection
Code requires an active waste and release reduction program, and reduced environmental impacts
that include an ongoing effort by others for promotion and support of these environment efforts
throughout the lifecycle of products.

An ongoing dialogue, communication, information sharing and feedback mechanism with

Gulf Petrochemicals & Chemicals Association

employees and the stakeholders will help in meeting the outreach obligations.
1.1 Suggested Activities / Examples
Example No. 1
Host meetings / workshops / seminars to promote dialogue and awareness with employees and
stakeholders and to demonstrate environment programs implemented along with the performance
data. Discuss the importance of employee and stakeholder contribution and support for environment
programs, resource conservation, household hazardous waste collection / segregation / recycle /
disposal, etc.

Example No. 2
Develop newsletters and posters; use the media and organization magazines to publish data
related to waste and release reduction, material utilization, reduction in environmental impacts,
environment programs and associated costs, and recycling programs.

Example No. 3
Provide environmental information to customers related to product usage, emissions, storage,
loading and unloading, waste handling and disposal.

Example No. 4
Share organization’s Responsible Care® experiences and environment programs with customers
and suppliers, business partners, industry committees and government agencies.

1.2 Self-assessment
• Is there information relating to the progress of wastes and release reduction detailed in official
company media, i.e., annual reports, newsletters, and website?
• Do representatives from the company participate in industry committees or government
agencies to promote exchange of environmental information?
• Does the company provide environmental training or awareness material for external use?

Implementation, Assessment and Improvement

EP-9: Monitoring and Reporting

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

1.0 Guidance
A major task in environment efforts is to develop a quantitative inventory of chemicals, wastes
and releases. This involves an evaluation of production processes with particular emphasis on
identifying, quantifying, and characterizing wastes and release reduction streams. The results of
these activities can provide a quantitative inventory of wastes and releases, and form the basis for
making informed decisions in setting priorities, plans, and goals.

An organization will need to prepare inventory of the quantities of routine and accidental releases,
and releases resulting from catastrophic or other one-time events of hazardous chemicals as well
as the maximum amount of hazardous chemical used, i.e., manufactured or processed on the
facility during the year and the wastes managed on the facility or transferred off the facility.
 Environmental Protection Code | 17

1.1 Suggested Activities / Examples

Example No. 1
Possible activities to comply with this Management Practice could be:
• Develop and maintain an inventory using existing information and data.
• Identify sources of multimedia wastes and releases.

Example No. 2
Appoint a competent person(s) to manage the quantitative inventory of chemicals, ensuring that all
waste streams are identified, recorded and updated periodically, based on risk.

1.2 Self-Assessment
• Is there a system to identify and maintain inventory records of wastes and releases?
• Do the inventory records show up-to-date and accurate data of all generated waste streams?
• Do the inventory records show up-to-date and accurate data of the various types of environmental
releases?

EP-10: Evaluation and Target Setting

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. It is suggested to carry
out this exercise at least annually, but can be on quarterly or less frequently.

1.0 Guidance
Tracking and measuring the progress of environment efforts are important for the success of any
improvement program.

Effective tracking and measuring can help to:

• Develop effective plans and establish credible goals.
• Measure progress against goals.
• Document the program’s effectiveness.
• Assure workers, the public and/or other relevant stakeholders that there is progress.
• Satisfy regulatory requirements.
• Track material loss.

1.1 Suggested Activities / Examples

Example No. 1
A company should regularly analyze the annual inventory records for an agreed number of years
and identify opportunities for future improvement.

1.2 Self-assessment
• Are the latest planned environmental performance targets monitored?
• Are management informed on the progress of reduction trend and inventory records?
• Are historic performances used as a comparison to identify key areas for improvement?
• Do operating instructions include early detection of abnormal environment parameters and
detail necessary and appropriate reporting and corrective action?
Gulf Petrochemicals & Chemicals Association

P-11: Environmental Review

Periodic evaluation of waste management practices associated with operations and equipment at
each company facility, taking into account community concerns and environmental impacts and
implementation of ongoing improvements. The Waste Minimization concept can be used, and
companies can adopt one of the industry practice that suits them.

1.0 Guidance
This Management Practice deals with evaluating waste management practices of company
facilities that extend beyond regulatory compliance. Activities that enhance a facility’s ability to
cope with change, to advance, and to reduce health and environmental impacts on the community,
employees, and surrounding area should be encouraged. Given the ever changing regulatory and
legislative climate, heightened public expectations, and increased financial liabilities, improvements
in a facility’s overall environmental program should be promoted.

This practice requires that each company has a mechanism in place such as waste minimization
program to ensure a systematic and periodic review of the facility’s operations that enables
companies to:
• Determine the facility’s compliance with existing environmental regulatory requirements – the
environmental compliance component.
• Further reduce or eliminate the facility’s wastes and releases - the waste management
component.
• As possible, include economic value on recommended waste minimization opportunity to
enhance the incentive for implementation.
• Review those aspects of a facility’s environmental program that go beyond regulatory
compliance, and implement improvements - the continuous improvement component.

Implementation of this practice can utilize on-facility personnel, contractors, and/or other off-facility
personnel.

1.1 Suggested Activities / Examples

Example No. 1
Establish frequency for conducting facility assessments of current waste management standards
and practices.

Example No. 2
Prepare for an on-facility review, which may include:
• Selecting a review team and assigning responsibilities.
• Assembling and reviewing background information.
• Preparing a checklist for on-facility review.

Example No. 3
Conduct an on-facility visit, which may include:
• Participation in a meeting with facility management.
• Performing facility assessments and observing operations.
• Assessing and reporting on environmental findings and recommendations.
• Evaluating progress with respect to the waste management practices.
 Environmental Protection Code | 19

1.2 Self-assessment
• Are there sufficient resources and expertise allocated to evaluate employee feedback and
neighbors’ concerns?
• Is an evaluation of waste management practices carried out at regular intervals?
• Are review findings discussed with senior management and effectively managed to close out?

EP-12: Contractor Competency

A process to ensure review of selected contractors and sub-contractors of sustainable disposal
practices, waste reduction focus and recycle efforts is required, further, continuous improvement
must be considered for waste management practices, including personnel safety and mitigation of
potential environmental impacts.

1.0 Guidance
The purpose of conducting these reviews of contractors and sub-contractors is to ensure the
responsible handling of wastes, drive continuous improvement of environmental performance of
external contractors and sub-contractors, and minimize the company’s potential environmental
liabilities.

Given the variety of commercial relationships and circumstances involved, companies are to
exercise their own judgment as to how to conduct reviews. Companies must be transparent of
their review process (es), and inclusive for all stakeholders. The following areas can be considered
while developing a review mechanism:

1. Management.
Structure, procedures, continuous improvement and awareness of sustainable waste reduction
initiatives, financial conditions, industrial hygiene & safety and community relations.
2. Regulatory considerations.
Regulatory compliance, permit status, enforcement actions, proper and thorough review of
past practices / litigation, agency relations.
3. Operations.
Operation and maintenance, facility practices and housekeeping appearance, programs for
proper management and reduction of types of wastes disposed and management, employee
awareness and training, record keeping, security and emergency response capability.
4. Physical setting.
Geology and hydrogeology, potential environmental impact and mitigation practices from or to
adjacent property and history / past use.

1.1 Suggested Activities / Examples

Example No. 1
Establish waste management requirements and capabilities into the technical tender selection
criteria of the procurement process.

Example No. 2
The tender review process should include a review of evidence provided by tenderers with respect
to waste management knowledge and previous practices.
Gulf Petrochemicals & Chemicals Association

Example No. 3
A process should be established to educate contractors on the company’s s continuous improvement
for waste management practices and to align both company and contractor practices.

1.2 Self-assessment
• Is there documented assessment criteria for selecting contractors involved in the environmental
aspects of company activities?
• Do selection processes include contractor’s awareness on regulatory environmental
requirements?
• Is past performance in similar work activities considered during the assessment?
• Is there a process established to monitor continual performance during the contract execution?

EP-13: Groundwater Protection

Verification of engineering and operating controls at each member company facility to continuously
improve prevention and early detection of releases that may result in groundwater impact.

1.0 Guidance
Groundwater protection has become an increasingly important issue. The public is concerned about
incidents of groundwater contamination, the potential risks posed by groundwater contamination, and
avoidance of future contamination. The objective of a groundwater protection program is to protect
the groundwater resource. Prevention of contamination is emphasized since it is more practical in
the long term to prevent the contamination of groundwater than it is to remediate or clean-up a
groundwater resource. Prevention of groundwater contamination is in a company’s interest due to
potentially adverse legal, financial, and public relations impacts from incidents of contamination.

Generally, groundwater protection programs are usually facility specific, and must be tailored to the
unique geographical and hydrogeological characteristics of each location (or facility) and hence it’s
potential impact to groundwater quality.

Engineering and administrative controls must be effectively implemented to ensure groundwater

protection.

1.1 Suggested Activities / Examples

Implementation of a groundwater protection program is usually a stepwise process that involves
the following examples.

Example No. 1
Facility assessment:
Facility assessment serves as a guide to planning groundwater protection activities. An assessment
can provide an understanding of a facility. Groundwater monitoring may be used to help compile
some of the physical and chemical characteristics data and to enable a facility to identify sensitive
areas that may warrant collection of additional data.

Example No. 2
Selection of priority alternatives:
Determination of priorities for addressing potential sources of groundwater contamination.
Protection planning should focus on the detection and prevention of releases from sources that
have the greatest potential to adversely impact beneficial uses of groundwater.
 Environmental Protection Code | 21

Example No. 3
Implementation of groundwater protection measures
The basis of groundwater protection is good engineering design and proper operating controls and
evaluation of the effectiveness of these protection measures.

Example No. 4
Ongoing management of the program
Ongoing management helps manage risks over the long term and helps maintain a company’s
ability to prevent and respond to releases.

1.2 Self-Assessment
• Is there a list of potential sources of ground contamination?
• Is there a recovery plan should ground contamination occur?

EP-14: Continuous Improvement

Implementation of a continuous improvement plan to effectively address past operations and
waste management practices is required. Decommissioning and decontamination programs must
be planned, effectively reviewed, implemented, and communicated to all stakeholders.

1.0 Guidance
The first step is to obtain sufficient knowledge about the given facility to make a decision regarding
what, if any, actions need to be taken to address potential health, safety and environmental
concerns resulting from waste handling, storage and disposal. This includes properties that are
still owned but no longer have ongoing operations. Inactive facility(s) must be investigated and
assessed to determine the need for any required remedial actions.

Stakeholder’s engagement is important, therefore continuous communication of issues, plans, and

progress to all stakeholders including contractors and sub-contractors is required.

If remedial action is needed, establish performance objectives based on various factors that may
include: stakeholders input, deadlines (regulatory, corporate, public), cost versus benefit, cost
versus time, permit requirements, corporate requirements and risk reduction considerations.

Consult with legal counsel regarding liability and insurance issues and take appropriate steps to
secure insurance cover if available.

Select preferred remediation option after consideration of such factors as: performance objectives,
relative risks, long-term liability, community concerns, regulatory requirements, costs and
technology availability.

Communicate issues, plans and progress to the regulatory agencies and the community, as
appropriate, throughout the above process of investigation and remediation to inform them and to
resolve their concerns.

Periodically monitor and evaluate effectiveness of remediation projects to assure resolution of

regulatory and community concerns and health, safety and environmental impacts, relating to
waste management. Carry out additional remediation as needed.
Gulf Petrochemicals & Chemicals Association

1.1 Suggested Activities / Examples

Example No. 1
Maintain a list of facilities which have potential environment impacts that could lead to employee
or community concerns.

Example No. 2
Prioritize facilities based on results of the facility past practices, review, community concerns, legal
requirements and potential EHS&S risks.

Example No. 3
Identify projects for highest priority facilities / locations including funding commitments, defined
project objectives, and timetables.

Example No. 4
Periodically review the priority list and remedial project performance against project objectives. As
projects are resolved, it may be necessary to reprioritize remaining projects.

1.2 Self-Assessment
• Has the company conducted an assessment of past operation(s) including any previously used
company owned disposal facilities, and documented the potential impact formally?
• Has the company identified a remediation strategy(s) based on the assessment?
• Does the remedial plan show willingness to assist regulatory agencies to assess non-company
operated disposal facilities, which the company has used in the past; with a view to co-operating
as appropriate in future actions?
 Environmental Protection Code | 23

CHAPTER THREE
References:
• Implementation Guide for Responsible Care® Environmental Protection Code of Management
Practices; American Chemistry Council.
• GPCA-RC-C07, Issue 15-06-2011.
• American Chemistry Council ACC RC 14001® 2015 TITLE: RESPONSIBLE CARE MANAGEMENT
SYSTEM® TECHNICAL SPECIFICATION
• ISO14001-2015 Environmental Management System
• American Chemistry Council RCMS®: 2013
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