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Item N° Question Guideline

1 Management System and Responsibility Management System and Responsibility

1.1. Management Responsibility Management Responsibility
1.1.1. Company Policies Company Policies
[Link] Does the company have a current written policy reflecting General note: In the SQAS questionnaires, the reference to a written policy, procedure or
management's active commitment to: record does not mean that the information should be in hard copy. Electronic supporting
evidence will be accepted.

[Link].a Safety & Health, The policy statement(s) must be clear and unambiguous concerning management’s
Environment, Quality/customers requirements, commitment to the safety of all operations, the health of the employees, the protection of the
Security, environment, the quality of the operations and services, the security (including Information
Behaviour Based Safety, Technology security) and meeting the customer's requirements at all times. There should be
Prohibition of drugs and Alcohol, evidence that the policy is reviewed, kept up to date, communicated effectively to the
Training development, employees and signed by the present managing director. If a policy topic is missing the assessor
Non conformance reporting? should indicate which one. All mentioned topics must be present in the policy to score YES.

BBS (or an equivalent programme) aims to increase safety during activities by positively
influencing the behaviour of operators/drivers through observation, coaching, communication
and feedback. BBS principles are applicable for every SQAS module. Details on BBS can be x x
found in the guidelines of section 3.3 of this questionnaire. It is envisaged that BBS programs
are an integrated part of the company SHE policy. Verify if specific reference is made in the
policy to Behaviour Based Program (as described in the CEFIC/ECTA BBS guidelines, brochures
or equivalent documents).

CEFIC guidelines can be found in this link : [Link]

safety-guidelines-training-drivers-safe-driving-road-freight-vehicles
Verify if it is explicitly stated in the policy that the use or being under the influence of any drug
or alcohol is prohibited during working hours.
For security : Protecting people, safeguarding the integrity of high value and hazardous
products against loss by intentional destruction or theft, and proprietary information given into
the custody of a logistic service provider is essential. Verify whether the importance of these
objectives are specifically mentioned in the policy.

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[Link].b Corporate Social Responsibility (CSR) requirements? CSR is a concept whereby companies integrate social, labour and human rights and governance,
safety and environmental concerns in their business operations and in their interaction with
their stakeholders (This is also valid for sustainable procurement). For more information about
CSR see [Link]

For Social: Fundamental human rights, working conditions and hours, non discrimination,
freedom of association , prohibition of people working under the minimum age required by
law. Verify if these topics are specifically mentioned in the policy.

For Governance: Fair business/business ethics (e.g. anti-corruption and bribery, conflict of X X
interest, fraud, money laundering, anti-competitive practices). Verify if these topics are
specifically mentioned in the policy.
For a glossary of CSR terms see the "Glossary of CSR terms" worksheet

[Link]. Are senior managers sufficiently visible and engaged in Documents have to prove an active leadership by taking the lead in e.g. presentations,
carrying forward the SHEQ&Sec message? interventions, discussing HSSE in staff meetings as well as with (sub)contractors. Indicate what
proof could be seen. x X

[Link]. Does the line management interact and constructively There should be evidence in senior and middle management communication and meeting
encourage employees to be actively engaged in SHEQ&Sec reports of following items :
performance improvement? - encouraging staff and contactors to show involvement in SHEQ&Sec issues
- the follow-up of HSSE metrics against HSSE target like incidents, near misses, occupational
illness case analysis. x x
Those should also be consequently discussed in the appropriate committee(s).

1.1.2. Roles & Responsibilities Roles & Responsibilities

[Link]. Is there an organization chart and associated job description
defining each individual's role within the organization,
including their responsibilities for SHEQ&Sec and CSR?

1.1.3. Legislation and other requirements Legislation and other requirements

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[Link]. Is there proof available that the company stays abreast of Look for documentary evidence in the form of an up to date register of relevant legislation . At
all relevant legislation and legislative developments in the a minimum this includes environmental laws, safety and health regulations, corporate social
area of SHEQ&Sec and CSR and are persons formally responsibility and other applicable regulations. Focus on changes in legislation. Ask the
designated or a source defined? company for examples of changes in legislation which happened during recent years if a new
assessment, and the last 3 years if a re-assessment, and check how the company implemented
them. If (a) person(s) is (are) formally designated, this responsibility should be clearly described
in a job description. If an external source is used, there should be clear evidence of a contract,
exchange of letters or some other form of written understanding, specifying the service to be x X
provided, when and to whom within the Company.
EU Directive : 89/391/EEC Art. 7 (Health and Safety)

[Link]. Is there a written procedure present which describes how Look for documentary evidence of communicated and implemented changes in the various
legislative changes as detailed in the register of legal applicable SHEQ&Sec & CSR management system documentation and registrations. Look also
requirements are communicated and implemented in the for communication/information to (relevant) employees.
company? EU Directive : 89/391/EEC (Health and Safety)
The company should ensure that its employees stay abreast of the regulations concerning the
products transported/handled. Customers and suppliers should be involved. EU Directive
98/24/ EC Art. 8 and amendments.

[Link]. Is a regular review made of the system for compliance with Look for evaluation documents and follow up of identified actions if any. This evaluation should
legal requirements ? be detailed towards new/adapted legislation and changes in operations.

[Link]. Does the Dangerous Goods Safety Advisor produce an Check that the Dangerous Goods Safety Adviser has produced an annual report by 1 July
annual report to Management on the Companies' activities (Industry requirement). The report summarizes the Company’s activities concerning the
in the transport of dangerous goods, in accordance with transport of dangerous goods for the previous calendar year. Score "1" if the report is on time
legal requirements and within six months after year end? and in compliance with the legal requirements. Score "N/A" only if no dangerous goods are
transported or loaded. Score "0" if the activity includes the transport or loading of dangerous
goods and no report is available before 1 July, even if there is no legal obligation. EU Directive
2008/68/EEC - ADR 1.8.3.

2 Risk management Risk management

This section includes Safety, Health, Environment, Security & CSR risk management and
regulatory compliance systems

2.1. Risk assessment and mitigation measures Risk assessment and mitigation measures

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Risk management is the identification, assessment, and prioritization of risks followed by
coordinated application of resources to minimize, monitor, and control the probability and/or
impact of unfortunate events.
A documented system should be in place to identify all risks associated with the company
operations; the risk assessment should meet the requirements of statutory legislation as well
as operational risks that are not covered by applicable legislation. The assessment to identify
and reduce risks should be supported by implementation of an action plan, this will make the
potential risks identified and measurable over a period of time in the operations. The system
should take into account all risks of possible accidents, incidents or releases to the
environment, which may cause human and/or environmental exposure. The risk assessment
and management system should examine the following questions:
- what are the hazards?
- what can go wrong?
- what is the probability that something will go wrong?
- what is the potential impact on people, property and the environment?
- what measures should/can be taken to reduce the identified risks as much as possible?
'- is medical care available and ensured in case of emergencies?
Risk management should be regarded as a continuous process. The process should be repeated
at regular intervals, based on practical experience and incident evaluation. High risk activities
should receive more frequent reviews. A risk assessment should also be carried out each time
there is a significant change in the operational activities (e.g. handling of new products, use of
new equipment, changes in operating procedures). New projects should be evaluated at an
early stage. The risk assessments for new projects should be carried out in close co-operation
with the chemical suppliers.
EU Directive : 89/391/EEC Art. 9

The "Best Practice Guideline for Safe (Un)Loading of Road Freight Vehicles" provides additional
information for use by the assessed company, regarding: interfaces at loading and/or
unloading; SULID; Non Standard Operations (NSO); egress and access; use of couplings; and
many more. The assessor can also use this information as guidance to evaluate any possible
major risks linked to the activities of the assessed company. Further reference is made to
Annex 7 of the above mentioned Best Practice Guideline.
In case of an assessment of a Transfer Terminal, the risks described in the "Cefic/ECTA
Guidelines on Safe Storage and handling of containers carrying dangerous goods and hazardous
substances" must be taken into account: [Link]
containers-carrying-dangerous-goods-hazardous-substance

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2.1.1. Is there a process to assess and document the Safety, To score a ‘yes’, a documented system (check for a matrix/schedule detailing ALL operational
Health, Environmental, Security risks and working activities) should be in place (see main comment above) to assess and manage the risks of both
conditions , related to all activities of the company, existing and new operations. Check if the process of risk assessment is repeated at regular
considering following aspects ? intervals (at least annually) for existing operations and takes into account practical experience
obtained during the operations and from incident evaluations. Check if a risk assessment has
been carried out each time there has been a significant change in the operational activities and
for every new project. Check the risk assessment report of two recent new activities or
projects.
In case of transport companies, refer to the Cefic guidelines "Guidance on Safety Risk
Assessment for Chemical Transport Operations". As a minimum the sections 5 "Qualitative
Analysis" (risk matrix) and 6 "Accident scenarios with potential high consequences" has to be
taken into account.

2.1.1.a start-up of new operations/activities (e.g. new products, The assessor should identify any new products recently carried, stored, handled or cleaned and
new routes) ? at the same time any new routes that products are transported over. These activities should be
verified by a risk assessment. The auditor should ask to see the DGSA report (if required) that
assesses the safety and environmental impact of new products before carriage or new services
that are planned. x x
EU Directive 98/24/EC and amendments.

2.1.1.b change of operations/activities (e.g. new products, new From conversation with auditees identify any work practice changes.
routes) Refer to the guidelines about management of change (MOC): "Managing Change in a Chemicals
Supply Chain": [Link]
supply-chain or equivalent.
Look for records of the risk assessment as indicated in section 5 of the guideline or equivalent. x x

2.1.1.c periodic review of risks on current activities? Current activities can be influenced by changing circumstances, legislation or incidents that
happened. Critical tasks should be reviewed annually, non critical every three years.
The assessor should check that the scope of the revision is in line with the activities defined in x x
the PAD.

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2.1.2 Are measures taken to control/mitigate all identified risks ? It should be checked whether the company has taken appropriate measures to mitigate the
risks identified in the risk assessment as much as possible, e.g. by:
- adequate operating written procedures
- selection of appropriate equipment
- route selection
- appropriate training
- emergency response arrangements
- adequate collective and personal protective equipment x x
EU Directive 89/391/EEC Art. 6. Reference to the guidance "Responsible Care Security Code",
item 2.5. This guidance could help to identify points to assess
[Link]

2.2. Safety Safety

2.2.1. Personal Protective Equipment (PPE) Personal Protective Equipment (PPE)
Please note that this section deals with PPE used by "OWN Personnel" and fully integrated
subcontractors. The controls over PPE of contract-personnel are covered in the section on
subcontracting.
[Link] Is there a written procedure defining what PPE has to be A very clear and comprehensive document, in accordance with the risk assessment, is
used under what circumstances ? expected to be available, defining in detail what PPE has to be used under what circumstances
taking into account the instructions from the customers. Scrutinize in detail! In case of a
transport service assessment, the Driver Manual can be accepted as “a very clear and
comprehensive document”, if it complies with these requirements.
The assessor should focus on the actual knowledge of the employees in the use of PPEs.
Findings in documents (positive or negative) must always be checked with drivers/operators
through interview.
Score 1 if the interview provides positive evidence. If records are clear but the interview
provides negative evidence, score 0. In these cases, it is recommended to add a comment
explaining the score.
In addition each operating procedure or instruction should specify what PPE, including any
training, should be used for each specific operation or product specific training requirement.
EU Directive 89/391/EEC Art.9. In case of transport companies, the PPE has to comply, as a x
minimum, with the standards indicated in the section 10 of the "Best Practice Guidelines for
Safe (Un)Loading of Road Freight Vehicles", unless local legislation has additional requirements.
PPE selection must be clearly based on chemicals handled and activities performed. Instruction
of customers are not always sufficient and should be evaluated by the carriers.

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[Link]. Is the PPE regularly checked (before use and at set intervals) The checking of equipment should be documented, with indication of the inspection date,
and replaced when required ? name of the inspector and comments. The auditor should ask to see an issue register for PPE
to employees, this can then verify re-issue of defective PPE equipment. The register should also
show the frequency of checks on PPE to verify condition.

[Link]. Are instructions and training provided when category III PPE Examples from type III PPE are : self contained breathing apparatus, filters, pressure suits,
or other specific precautions are needed and used? harnesses, … For specific chemicals such as PEG in case of phenol handling, calcium gluconate
in case of Hydrofluoric acid handling etc. special precautions and training are needed. x
Regulation (EU) 2016/425 - 89/391/EEC

2.3 Health Health

2.3.1 Are current Safety Data Sheets, available on site from the A product acceptance written procedure should be in place asking for the product safety data
manufacturers for all products transported and/or handled? before the product is handled. Product safety data should be supplied by the
consignor/manufacturer and maintained as current at all times, including compliance with
REACH/CLP by the consignor/manufacturer. Check the accessibility of this information at the
site (e.g. a file with the Safety Data Sheets of all the products transported or handled). Check at x
random the available information for a few products.
For distributors, SDS will also include those for products diluted and blended on site.

2.4 Security Security

2.4.1 Is there a system to monitor entry, exit and to limit access Give a positive score for any effective control method, e.g. security guard, electronic card entry
to restricted areas of all personnel and visitors through system, registered entry, etc. Limited access to restricted areas should be in place.
positive identification ? Reference to the "Responsible Care Security Code", item 3.1. The guidance could help to
identify points to assess [Link]
%20-%[Link]

2.4.2 Is there a written procedure in place, requiring documented Check the availability and the use of periodic inspection sheets or security check lists and verify
periodical inspections, to identify breaches in the security of the reporting of incidents and its remediation. x
the buildings/premises?

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2.4.3 Has a risk assessment been conducted in the last twelve Verify that the risk assessment has been undertaken. Verify that the company has
months, as a minimum frequency, regarding data on implemented protection measures on data, e.g. on EDI links , order processing and use of
customers, products and operations and are measures customer order details on an Internet site. EDI (Electronic Data Interchange) is the computer-
taken to mitigate identified risks? to-computer exchange of business documents in a standard electronic format between
business partners. If this task is outsourced, the assessor will ask for the contract with the
supplier and will check that the subjects mentioned below are covered.
At least, the following risks must be taken into account to protect data:
- Hacker attacks
- Infectious malware (software which is specifically designed to disrupt, damage, or gain
authorized access to a computer system)
- Security of business information on mobile devices (portable PCs, Tablets, cellular phones,
etc.).

2.4.4 Is there an inventory of Information Technology assets Assets include hardware (any device that can keep data, like laptops, mobile phones, cameras,
containing confidential company data? etc.) and software that handles information. An inventory of these assets must be drawn up,
maintained and kept up to date. Equipment and assets off-premises have to be included.

2.4.5 Is there a proactive maintenance program on Information The maintenance program has to be designed according to the supplier's recommended service
Technology assets handling information technology? intervals and specifications. It should include hardware and software. Records must be kept.

2.4.6 Has the company evaluated the risk of unauthorized This risk of unauthorized entrance of refugees should be evaluated even if the company is not
entrance (including refugees) to company premises, in a "hotspot".
transport equipment, tank cleaning facilities, storage areas Cross country borders and routes used by refugees should be taken into account.
or information processing facilities on site? Security perimeters have to be defined and used to protect areas that contain either sensitive
or critical information and information processing facilities (i.e. the room where IT servers are
kept).

2.4.7 Is a system in place to ensure that communication dialogue Check how security threats are communicated to employees and contractors. The system
and information exchange on security issues is appropriate? should include information to employees and management when the threat level changes.
A system to exchange information with local / national law enforcement agencies should be in
place. Refer to "Responsible Care Security Code" guidance, section 5.

2.4.8 Is a system in place to ensure that response to security Check reporting and action plans for security incidents / threats. Refer to "Responsible Care
threats and incident are defined? Security Code" guidance, section 6.

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2.5 Fair business practices

2.5.1 Has the company formalized the fair business practices ? To score positively, the following mechanisms have to be covered: Risk assessment on business
ethics conducted on the upstream supply chain to define policies, communication of Code of
Ethics/business ethics policy to all employees, communication of Code of Ethics/business ethics
policy to business partners (e.g. suppliers).

2.5.2 Are there mechanisms in place to ensure effective To score positively, the following mechanisms has to be in place: signature acknowledgement
implementation of the anti-corruption and bribery policy of anti-corruption policy required for all concerned employees, specific approval written
(including for instance: conflict of interest, fraud, money procedure for sensitive transactions (e.g. gifts, travel), specific procedures for retaining and
laundering)? using third-party intermediaries (i.e. due diligence, certifications), structured mechanisms to
deal with policy violations (e.g. potential sanctions), secure communication channel for
employees to seek advice or voice concerns (e.g. hotline, whistle blowing procedure), internal
audit on compliance with anti-corruption and bribery policy, internal controls (e.g. four eyes
principle, separation of functions, job rotation). X X
To score positively, the company should have established effective and appropriate internal
controls to identify and prevent corruption (e.g. multiple-eye principle, specific approval
procedure for sensitive transactions (e.g. financial benefits).

2.5.3 Are there mechanisms in place to ensure effective To score positively, the following mechanisms has to be in place: signature acknowledgement
implementation of the anti-competitive practices policy? of anti-competitive practices policy required for all concerned employees, structured
mechanisms to deal with policy violations i.e. potential sanctions, awareness or training
program on anti-competitive practices (e.g. cartels, price fixing, bid rigging), internal audit on
compliance with anti-competitive practices policy. X

2.6 Environment

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2.6.1 Is the classification, storing, segregation, identification, All wastes: general, non-hazardous and hazardous have to be classified, stored, labelled,
protection and final destination of any generated waste, segregated, protected from rain (if applicable) and disposed of in a safe, practical and legally
done according to legal regulations and only by legally compliant manner through persons, organizations and sites with the correct licenses, where
approved waste management companies? legally required. The assessor has to check that waste disposal records are retained as per legal
requirements. Waste carriers, dealers and brokers should provide evidence of correct
registration or authorization.  The route of disposal and final destination of the waste should be
ascertained.
Samples that do not need to be stored any more and any used packaging material generated on
site are also considered waste.

2.6.2 Has the company carried out a risk assessment taking into Look for documentary evidence. In many countries periodical soil monitoring is necessary:
account the impact of company activities on soil and check the last report. Check that preventive/corrective measures have been implemented, if
groundwater contamination? the risk identified is not acceptable.

2.6.3 Where plastic/flakes/powder are transported/handled in Very small particles of plastic/flakes/powder that are lost during transportation, handling,
bulk or packaged forms, has the company signed up to cleaning or storage can have a negative impact on the aquatic environment if they reach rivers,
"Operation Clean Sweep" or "Zero Pellet Loss" or similar lakes, or the sea.
programmes? The programmes mentioned in the question are:
Operation Clean Sweep: Is an international programme designed to prevent the loss of plastic
granules (pellets) during handling by the various entities in the plastics industry and their
release into the aquatic environment [Link]
Zero Pellet Loss programmes: Programme from the Plastics Packaging Industry Association:
[Link]
See also Cefic /ECTA Guidelines "Safety and Quality Best Practice Guidelines for
Unloading of Polymers in Bulk", item 5: [Link]
safety-quality-guidelines-for-unloading-polymers-in-bulk

2.6.4 Has the company asked the applicable subcontractors to This is applicable to transportation, handling, cleaning or storage subcontracting
sign the programmes mentioned in 2.6.3 where the
company transports/handles plastic/flakes/powder?

2.6.5 Is there a programme in place to measure and reduce pro An effective programme should be in place for the measuring of consumption of resources by
rata the use of the following resources in fixed the company. On top of this an improvement plan should be set up to optimize their use and
installations?: there is evidence that this is actively monitored.

2.6.5.a electricity

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2.6.5.b fuel e.g. diesel, gasoline, natural gas/LPG
2.6.5.c water
2.6.6 Is a programme in place to measure and reduce pro rata An effective system should be in place for measuring the emissions from the company. This can
the output of emissions? be CO2, dust, noise, SOx, NOx, … . A programme that shall lead to the reduction of these
emissions should be in place and monitored.
In case of Transport Service assessments, this question has to be scored taking into account x
both the questions in SQAS TS section 9 and the emissions from fixed installations.

2.6.7 Is a programme in place to measure and to reduce pro rata An effective system should be in place for measuring and reducing the waste of the company,
the waste generated by the company activities? e.g. waste oil, scrap metal, old batteries, cargo residues, waste water, etc.

3 Human Resources Human Resources

3.1 Recruitment Recruitment
3.1.1 Is there a written recruitment procedure which takes into Score "1" only if there is a written recruitment procedure for all functions and proof of the
account relevant experience, competence and education for application of this procedure. Employees with different functions in the company should be
all employees, including temporary staff? checked.

3.1.2 Have all operating personnel (drivers, operators, etc.) Check for evidence that all relevant operating personnel have undergone such a periodic
undergone a periodic medical examination where required medical examination. This examination should be adapted to the risks inherent to the tasks of
by law or by the risk assessment of the job? the operators. If the law allows operating personnel to refuse a medical examination, check
that any consequential legal requirements are fulfilled; in this case the score will be zero with a x
mandatory comment from the assessor.

3.1.3 Is there a written grievance and disciplinary procedure? Grievance is a complaint by an employee about an action, which his employer has taken or is
contemplating taking in relation to him. The grievance and disciplinary procedure should be a
written one and communicated to all employees. It should include what actions are required
for raising a grievance and what sanction will be applied in different cases and should focus on
SHEQ&Sec and CSR . Verify by asking a sample of employees the content of this procedure.

3.2 Training Training

If fully integrated subcontractors are used these drivers/operators should be included.

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3.2.1 Is there a training programme in place for all personnel that A training programme is the overall procedure on training. A training plan is the output list of
results in an individual training plan and are records training to be followed. This question is about the programme and plan, but the
available that the training plan has been implemented? Is implementation has to be in compliance with local legislation. For new employees, the
the training plan reviewed annually? programme shall include an induction training.
Look for up to date training records and individual proof of the implementation of the training
programme. If the training programme or training plan could not be followed, clear evaluations
should be available to explain the discrepancies in combination with corrective actions. EU
Directive : 89/391/EEC Art. 10. x x
Some tasks/activities may require a specific knowledge, experience or education. Discuss
whether a conscious effort has been made to assign qualified people for specific (technical)
aspects of the business, where required. The risk analysis is a basic document to identify such
tasks.

3.2.2 Are the following subjects being trained: Check at random a sample of training records to confirm that the subjects mentioned under
sub questions a to n are covered. The extent of this training should be in relation to the risks
that the different employees are faced with and which are identified in the risk assessment, as
mentioned in question 2.1.1. Frequency of the training depends on risk assessment and the
employees individual performance but all subjects mentioned in the sub-questions have to be
covered on a maximum five years cycle.
EU Directive : 89/391/EEC Art. 10
The "Best Practice Guideline for Safe (Un)Loading of Road Freight Vehicles"
[Link]
vehicles can be used to define in more detail how the training programme for LSP's is set up

3.2.2.a - incident reporting, investigation and analysis? The training programme should cover responsibilities, notification processes, classification, and
root cause analysis. In order to determine who will be trained and the extension of the training
the Cefic/ECTA/Fecc "Guidelines for investigating logistics incidents and identifying root
causes" could be used x
[Link]
causes-en

3.2.2.b dangerous goods handling? Score "N/A" if no dangerous goods are handled. To score a "1" training must cover at least all
legal requirements linked to the areas of the company's scope, e.g. ADR, ADN, RID, IMDG, GHS,
etc. EU Directive 98/24/EC Art. 8 and ADR 1.3.

3.2.2.c specific product or handling needs? Not only dangerous goods could present dangers but also other products or handling can cause
certain risks. Giving training on these issues should be a part of the prevention measures
mentioned in the risk analysis.

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3.2.2.d use of PPE (Personal Protective Equipment)? The training programme should cover the company PPE policy, and the use and replacement of
equipment. Training program/records must explicitly show the content of the program. Focus
on the actual knowledge of the employees in the use of PPE. The PPE used have to be in line
with the risk assessment carried out. Findings in documents (positive or negative) must always
be checked with drivers/operators through interview. Score 1 if the interview provides positive
evidence. If records are clear but the interview provides negative evidence, score 0. In these x
cases, it is recommended to add a comment explaining the score.

3.2.2.e company emergency written procedures? The training programme covering emergency procedures should include practical as well as
administrative aspects. x
3.2.2.f spill prevention and control? The training should include loading and unloading procedures and the actions required by
operators and drivers in the event of a spillage. In the case of intermodal transport, an
important aspect of the control also concerns the check on all openings e.g. manlid and valves
for no leaks, integrity of the tank during the transit, which includes the check on the Interface
locations, like rail terminals and seaports. The driver has to check when a container is picked- x
up or dropped-off.

3.2.2.g Behaviour Based Safety (BBS) principles? Training covering BBS should be in alignment with principles as described in CEFIC/ECTA BBS
guidelines: "Behaviour Based Safety Guidelines for training of drivers and safe driving of road
freight vehicles" and "Best Practice Guideline for Safe (Un)Loading of Road Freight Vehicles" or
equivalent and include at least : observation, key performance indicators, individual
performance and re-training.
See [Link]
vehicles x x
It is recommended that non-transport companies proactively implement their own BBS Plan,
based on the principles of equivalent programmes in Transport.

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3.2.2.h security awareness proportionate to the risk and their role Security awareness training shall address the nature of security risks, recognizing security risks,
within the business (Security of information should be methods to address and reduce such risks and actions to be taken in the event of a security
included)? breach. It shall include awareness of security plans (if appropriate) according to the
responsibilities and duties of individuals and their part in implementing security plans. Training
program/records must explicitly show the content of the program. In the case of transport
companies, their planners and drivers have to be interviewed.
The assessor has to focus on the actual knowledge of the employees about the risks aspects
mentioned in the guidelines (e.g. protection of information and goods). Findings in documents
(positive or negative) must always be checked with employees through interview. Score 1 if the
interview provides positive evidence. If records are clear but the interview provides negative
evidence, score 0. In these cases, it is recommended to add a comment explaining the score.

3.2.2.i risk Assessment and risk Management? In case of transport companies, consult the "Guidance on Safety Risk Assessment for Chemical
Transport Operations". Specific reference is made to Annex 1 of the "Best Practice Guideline
for Safe (Un)Loading of Road Freight Vehicles".
Identify the persons in the company who carry out risk assessment: Safety / Environment /
Security responsible, planners, etc.: have they attended training in risk assessment?
In case of transport companies, expect the drivers training to be provided at operating and x
practical level.

3.2.2.j communication skills? Drivers, operators and, where applicable, other employees shall have knowledge of the
applicable expressions in English. Refer to section 6 of the "Best Practice Guidelines for Safe
(Un)Loading of Road Freight Vehicles".
[Link]
vehicles

3.2.2.k all aspects related to prevention of bribery and corruption?

X

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3.2.2.l training in awareness of fatigue and tiredness? This question applies to all operational personnel who could be affected by fatigue and/or
tiredness.
"Fatigue" in the understanding of this question is meant as deterioration in mental or physical
performance due to prolonged physical or mental work - it occurs even in people who have had
adequate sleep. All that may be needed to recover from fatigue is a rest from this work, or a
change in activity ("a change is as good as a rest"). Sleep may not be needed if adequate sleep X
has already been taken.
"Tiredness" or sleepiness is the likelihood of falling asleep, due to inadequate sleep, prolonged
wakefulness, or working through the night.

3.2.2.m company ethics policy / code of ethics?

3.2.2.n training and Awareness about impact of Very small particles of plastic/flakes/powder that are lost during transportation, handling,
plastic/flakes/powder loss, where the company cleaning or storage can have a negative impact on the aquatic environment if they reach rivers,
transport/handle these products lakes, or the sea.
The programmes available are:
Operation Clean Sweep: Is an international programme designed to prevent the loss of plastic
granules (pellets) during handling by the various entities in the plastics industry and their
release into the aquatic environment[Link]
Zero Pellet Loss programmes: Programme from the Plastics Packaging Industry Association:
[Link]
See also Cefic /ECTA Guidelines "Safety and Quality Best Practice Guidelines for
Unloading of Polymers in Bulk", item 5: [Link]
safety-quality-guidelines-for-unloading-polymers-in-bulk

3.2.3 Is a first aid training programme defined for identified Verify even if not regulatory required, that the first aid training programme is documented and
persons and implemented ? implemented (including refresher training). Check for participants and frequency. If required
by legislation : verify the compliance in addition to the above. The assessor must identify in the
comments if the first aid of the assessed company is covering a) an office set up only, or b) an x
operating site.

3.2.4 Are variances from the plan effectively followed up? Example: illness or unexpected absences for any other reasons. New hires and job rotation
shall also be considered.

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3.2.5 Is the effectiveness of the training checked for each Proof has to be available that shows that the effectiveness of the training was checked. This can
employee ? be a test after the training, an evaluation of the work of the employee a certain time after the
training, an output measurement of the performance of the employee.

3.3 Behaviour Based Safety (BBS) Behaviour Based Safety (BBS)

BBS guidelines already exist "Behaviour based safety guidelines for training of drivers and safe
driving of road freight vehicles " and "Best Practice Guidelines for Safe (Un)Loading of Road
Freight Vehicles", section 1: [Link]
loading-of-road-freight-vehicles
It is recommended that non-transport companies proactively implement their own BBS Plan,
based on the principles of equivalent programmes in Transport.

3.3.1 Has a BBS implementation plan, or an established Check for a documented implementation plan or an established programme including targets
programme, been set up with targets, resourcing and and up to date status mentioning results. The targets could be included in the general
timeline? objectives of the company. If there is any doubt, assess this question after assessing the BBS
section of the specific SQAS modules.
In the case of Transport Service and Warehouse assessments the "Best Practice Guideline for
Safe (Un)Loading of Road Freight Vehicles", Part A, chapter 1, should be taken into account to
determine the level of implementation of the 4 BBS levels given in the Guideline. Assessed
companies that are not directly involved in (Un) loading of road freight vehicles could use the x x
guidelines to have an equivalent programme in place to evaluate this level on implementation
The assessor should record in comments the BBS level that the company has in place.

3.3.2 Have the respective responsibilities of all personnel in the Look for role descriptions referring to the following responsibilities in relation to BBS.
implementation of BBS been identified ? Management are mainly responsible for the implementation and ongoing support of the BBS
program. They should have defined roles, delivered resources, and removed barriers to a
successful implementation, with results monitored against targets. Administrative personnel
should understand and support the BBS program in order to avoid / eliminate planning and
instructions which may be in conflict with the BBS principles. Trainers do not only execute the
BBS training but they also collect data and report the results to management. All staff should
understand the purpose of the BBS program, be positively committed to participate and accept
preventative changes as a result of the BBS findings and analysis.

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3.4 Labour Policy and human rights
3.4.1 Are specific mechanisms in place to ensure effective The following mechanisms should be in place: Transparent recruitment process (communicated
implementation of your company's Career Management clearly and formally to all candidates), regular assessment (at least once a year) of individual
and training policy? performance, setting of Individual development and career plan for all employees, official
measures promoting career mobility, policy to give priority to internal recruitment, provision of
skills development training, official measures to anticipate or reduce layoffs and associated
negative impacts (e.g. financial compensation, outplacement service).

3.4.2 Are specific mechanisms in place to ensure effective The following mechanisms should be in place: company public commitment to avoid
implementation of your company's non discrimination discrimination (e.g. colour, race, gender, religion, ethnic, social), company proactive measures
policy to avoid discrimination during recruitment phase, company specific awareness and training
programs for managers, company specific targets (exceeding legal requirements) to employ
disabled people, work conditions and provision of work stations adapted to disabled, company
specific measures to promote gender equality in the workplace (i.e. network groups, programs X x
for advancement of women, equal pay, etc.), whistle blowing procedure (employee's report of
suspected wrong doing at work) or disciplinary measures enforced.

3.4.3 Are specific mechanisms in place to ensure effective If there are legal requirements covering this subject, the company must comply with them. If
implementation of the company's policy about child labour? there are no legal requirements the following apply: No children below the age of 14 or 15
years should work except for apprentices, summer jobs, school or education. It must be
ensured that young workers below 18 are not harmed with regard to health, safety, security or
moral. The combined hours of transportation (to and from work and school), school attendance
and work have to be less than 10 hours a day. The assessor has to record the age of the X
youngest employee at the site or office assessed.

3.4.4 Does the company ensure that no forced, bonded or No guidelines.

involuntary prison labor is employed?

4 On/Off Site Emergency Preparedness and On/Off Site Emergency Preparedness and Response
Response Where a Transport Service, ESAD distributor or Rail assessment is taking place, both On Site
and Off Site emergency response (ER) plans will be required. For other service providers only
the On Site ER plan will be demanded.

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4.1 Is there a written plan for dealing with on-site and off-site The written emergency plan should cover all applicable scenarios, all items indicated in 4.2 and
emergencies and potential crises? shall be regularly updated. Check if all the described arrangements are in place. Verify if
Note: Text underlined is only applicable when an off site ER individuals understand their specific responsibilities in case of an emergency. The emergency
plan is required, on top of the ER plan on-site response plan should also contain any customer specific contacts on a 24/7 basis. An
emergency may turn into a crisis. Check that this crisis plan which may be part of the
emergency plan.
This question is also applicable for service providers that only subcontracts other companies.
The service provider can forward the requirements to their subcontractors, but it is their
responsibility to test or check whether their subcontractors are able to deal with emergencies
as defined.
The assessor should look for a written plan detailing the response by the company (or a x
contracted company) similar to ICE Level 3 response. This ER Plan must be able to cater for the
recovery of damaged equipment, the recovery of product and the containment and mitigation
of any spill. This service may be undertaken by an external 3rd party emergency responder who
has been formally appointed.

4.2 Does this written plan contain the following information :

4.2.a individual responsibilities ? The assessor should check that responsibilities from top management down to the Incident
supervisor are clearly defined, this being to assist with clear lines of demarcation and reporting.

4.2.b arrangements for 24/7 hours coverage by trained The assessor should ask for a register of Incident supervisors and what method is used to
responders ? obtain 24/7 coverage. From this point questions should be asked of the incident supervisors
onsite as to 24/7 coverage and the receipt by them of the schedule for 24/7 coverage.

4.2.c a list of the different parties to be informed with their The emergency response plan should detail parties to be informed in the event of an
contact details (customers, authorities) ? emergency, both internally and externally.

4.2.d a written procedure for handling the information towards Check that this procedure is incorporated into the emergency plan. The different
the neighbourhood, the press and other interested parties responsibilities and competences should be mentioned as well as training needed by those
of serious accidents/incidents that happened on site? employees dealing with communication and information. Look also for an up to date list of
contact numbers of applicable parties.

4.3 Is the emergency equipment maintained, tested or checked Fire hoses, fire extinguishers, eye bottles, emergency showers, breathing apparatus, first aid kit
on a regular basis? should be maintained/checked/tested on regular basis. The interval depends of the equipment
and the local legislation. Proof can be seen on the equipment or in an adequate report.

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4.4 Has there been a comprehensive test of the emergency plan Evidence of a practical emergency exercise to test the system for on-site and off-site
for on-site and off site emergencies during the past 12 emergencies during the last 12 months is required.
months ? For off site emergencies, such an exercise may be limited to the testing of the emergency
communication system and the actions to be taken on-site to deal with an off-site incident (it is
not required to do a simulation of an off-site emergency). A detailed evaluation report of a real
off-site incident during the last twelve months would also meet the requirements of this
question.
A possible test can be : Phone a driver, he should search for a parking area and call back. Then
interview with a particular checklist
a) explain to driver what has happened, like a valve is leaking x
b) ask driver what he has to do
c) compare with the checklist
d) conclusion, what was missing, plan for improvement e.g. training, date, signature.

4.5 Is there a documented business continuity plan and does This is a plan to ensure that operations continue in case of business disruptions/catastrophes
this plan contain the customer contacts to be informed ? due to different reasons.

5 Performance Analysis and Management Performance Analysis and Management Review

Review
5.1 Non-conformance reporting, investigation, analysis and Non-conformance reporting, investigation, analysis and corrective action
corrective action
Data should be available at every phase of the business from identifying new business through
to customer reaction and feedback. The collection and analysis of data can indicate means of
improving the service or conversely, can detect the onset of a reduction in the quality of
service before it becomes a major issue. To verify the satisfactory operation of the reporting
system, several sources of information should be checked such as reports to insurance
companies, customer complaints and fines, feedback from internal observations (e.g. drivers).

5.1.1 Is there a documented system in place for recording non- This question (items a to h) only scores positively if there is a documented system in place for
conformances regarding : recording , clarifying what is a non-conformance, who must report, how and to whom. These
questions are applicable for all domains such as environment, safety & health, quality, security
and CSR.

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5.1.1.a accidents & incidents ? Accident : An unplanned event that did result in quality loss, injury, illness, or damage
Incident : An unplanned event that could have resulted in quality loss, injury, illness, or damage
If dangerous goods are involved, ADR § 1.8.5. could be relevant. Check also if these events are
taken into account in the DGSA report. x x

5.1.1.b breaches of security and threats? Every event involving security breaches or threats such as theft, vandalism, entry without
authorization, unwanted access to ICT systems,. should be recorded and dealt with. x

5.1.1.c unsafe behaviour & unsafe conditions ? Situations or behaviour that did not result in quality loss, injury, illness, or damage, but have
the potential to do so are to be registered and given a follow-up. The number of records
available should be confirmed by the assessor during the site inspection.
If there are no records in the file the assessor should take into account any evidence found x
during the visit of unsafe behaviour or conditions and scores this question zero.

5.1.1.d regulatory compliance? e.g. observed overdue implementation of new regulatory requirements and fines.
x

5.1.1.e product contamination ? Self explanatory

x
5.1.1.f product discrepancies and shortshipments ? Every product discrepancy or shortshipment (outside the normal operations) are considered

5.1.1.g corruption & bribery ? The assessor should ask to see the files recording any non-conformances. If the file is empty
and the company states that there are no non-conformances, the assessor should write a
comment. If the company claims that these records are confidential, the assessor should score X
0 and record a comment

5.1.1.h grievance and disciplinary findings? The assessor should ask to see the files recording any non-conformances. If the file is empty
and the company states that there are no non-conformances, the assessor should write a
comment. If the company claims that these records are confidential, the assessor should score X
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5.1.2 Is a detailed report on non-compliances provided to the A criteria to define when a non-conformance will open an investigation on root cause analysis
responsible management, containing immediate cause, root has to be defined.
cause and recommendations for corrective actions to Verify that there is a defined written process/procedure for the recording, investigation, root
prevent recurrence? cause analysis and corrective actions to be taken, with time scales for actions. Refer to the
"Guidelines for investigating transport accidents/incidents and Root Cause Analysis". In these
cases, a detailed written report should be prepared for the responsible management without x
undue delay and in alignment with the internal procedure. Verify if the company has a system
to check effectiveness of corrective actions.

5.1.3 After an incident/accident are the employees and The feedback from an incident to all employees and contractors concerned is important to
contractors concerned informed and if necessary trained learn about the event and to prevent future occurrence. The root cause analysis should be the
with the aid of a Root Cause analysis? basis for such feedback and information. Verify if employees are aware of incidents and
prevention measures. Root cause analysis should also cover security incidents x

5.1.4 Is there a procedure in place to inform the customer Check from records that the customer concerned is properly informed, when his shipment is
promptly of all non-conformances involving his involved, and that this is done on a routine basis. Score "0" if it is not done consistently
shipments/products? x

5.1.5 Is the DGSA involved after an incident where dangerous Check incident reports as well as the annual report of the DGSA.
goods were involved? ADR 1.8.
5.2 SHEQ&Sec & CSR Objectives and Trend Analysis SHEQ&Sec & CSR Objectives and Trend Analysis
5.2.1 Is there a process in place to monitor and analyse An effective system should be in place for the recording and analysis of data, which allows for
SHEQ&Sec & CSR data to identify trends, to set objectives the identification of trends in the number of SHEQ&Sec & CSR non-conformances.
and is there an action plan in place to achieve these Check evidence that such a system exists. Ask to see a summary of the trend analysis for the
objectives ? last year(s). If a company has already been assessed, data should be available for the last three
years, which should document continuous improvement on the issue. If not, this question must
be scored with "0".
Examples of CSR objectives can be number of transport and/or occupational accidents, x x
damages to the environment, people trained, number of internal/external audits, etc.
Big companies can use “consolidated” reports including data from their subsidiaries, but
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5.2.2 Has the Safety, Health, Environment action plan of the Check if an approved Responsible Care programme has been implemented
company been reviewed against the applicable Responsible The plan of the company has to be reviewed against it (there exists a Responsible Care
Care Programme ? programme managed by ECTA for transport companies, cleaning stations and warehouses). In
the applicable RC Programme it is described how such a review is organized, e.g. annual
submission to ECTA or relevant National Association / Fecc European Responsible Care
programme for distributors.
Refer to:
[Link] x
[Link]
programme/

5.2.3 Does the company promote the principles of Responsible One of the success factors of RC is the promotion of the programme into the supply chain. The
Care to logistic partners? company should promote its logistic partners actively to join this RC programme.
x x

5.3 Internal Audit Internal Audit

5.3.1 Is there a documented plan for internal auditing of all areas Fully Integrated Subcontractors (FIS) should be included in the audit programme.
referred to in SQAS and covering compliance with For an effective control of the Management Systems it is necessary to audit each stage of the
applicable legislation and permits? management system. Such audit(s) should be thorough and comprehensive. The audits have to
cover the information technology system, as well. The assessor should look for a written audit
plan indicating a detailed system. A document detailing what will be audited, the frequency
and who will do it must be available. Look specifically if the areas (chapters) as referred to in x x
SQAS are sufficiently covered.
The actual situation of the company should be compared with the applicable legislation and the
permits.

5.3.2 For non-conformances identified in the audits, are action Ask to see minutes, memos, and reports documenting that the action plans are developed,
plans developed and are corrective actions taken ? followed-up and proper corrective action taken. The company should have a documented
system to validate the effectiveness of measures taken. x

5.3.3 Do those carrying out auditing have training and/or Internal audits should be conducted by people trained in auditing and evaluating techniques,
competence in auditing and evaluation techniques ? be independent of the activity being audited and at the appropriate level within the
organization. Ask for objective evidence (course attendance, syllabus, diplomas, organization
chart, experience, competence evaluation, etc.)

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5.3.4 Are safety walkabouts carried out and documented by Safety walkabouts are internal periodical safety inspections. The Senior Manager is the highest
appropriate managers on a periodical basis? level manager with operational responsibility at the site. Therefore it is important that they
participate in SHE inspections. A walkabout every three months is a minimum. x

5.4 Management Review Meetings Management Review Meetings

5.4.1 Is a formal management review meeting held at least once Check for evidence that a formal management review of the management system is held, at
a year to review the management system that includes, as least annually, to evaluate the overall effectiveness of these systems.
minimum, the following inputs?: Big companies can show “consolidated” management review reports including information
from all their subsidiaries, but analysis of the management systems of the assessed subsidiary x x
shall be available.

5.4.1.a the status of actions of previous Management review No guidelines.

meetings
5.4.1.b the DGSA Annual report (if applicable) No guidelines.
5.4.1.c the performance of subcontractors No guidelines.
5.4.1.d the effectiveness of the training programme No guidelines.

5.4.1.e the audit results No guidelines.

5.4.1.f the monitoring of trends of SHEQ, Sec &CSR KPIs, BBS KPIs No guidelines.
and Responsible Care KPIs (if applicable)

5.4.1.g the extent of which SHEQ, Sec &CSR objectives have been No guidelines.
met

5.4.1.h the effectiveness of the programmes about resources No guidelines.

consumption optimization required by question 2.6.5

5.4.1.i the effectiveness of the programmes about emission No guidelines.

reduction required by questions 2.6.6

5.4.1.j the effectiveness of the programme about waste reduction No guidelines.

required by question 2.6.7

5.4.1.k the outcome of the last SQAS assessment (if applicable) No guidelines.

5.4.1.l the outcome of the emergency response drills No guidelines.

5.4.1.m recommendation(s) for improvements No guidelines.

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5.4.2 Did the senior management consider the recommendations
of 5.4.1. and define an improvement action plan with
allocated actions and due dates?

5.4.3 Does senior management monitor progress versus targets It should be evidenced that at every relevant management meeting held by senior
on SHEQ&Sec & CSR matters at relevant management management SHEQ&Sec & CSR matters are monitored regularly versus objectives and set
meetings? targets. Verify if this is done. Who is the responsible Senior Management has to be defined. x

5.4.4 Is there evidence that learning points from SHEQ&Sec There should be a process in place between the management and employees on SHEQ&Sec to
issues are shared with the workforce ? share learning and to raise any issues of concern. Ways to achieve this may be through toolbox
talks or one to one discussions. Ask for objective documented evidence that feedback is shared
and input from employees is encouraged. x

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Glossary of CR terms:

Life balance:
Is a concept including proper prioritizing between "work" (career and ambition) and "lifestyle" (health, pleasure, leisure, family and spiritual
development/meditation)

Layoff:
Also called redundancy in the UK, is the temporary suspension or permanent termination of employment of an employee or (more
commonly) a group of employees for business reasons, such as when certain positions are no longer necessary or when a business slow-
down occurs
Whistle blowing procedure:
Whistleblowing is when a worker reports suspected wrongdoing at work. A worker can report things that aren’t right, are illegal or if anyone
at work is neglecting their duties

Collective bargaining :
Is a process of negotiations between employers and a group of employees aimed at reaching agreements that regulate working conditions.
The interests of the employees are commonly presented by representatives of a trade union to which the employees belong. The collective
agreements reached by these negotiations usually set out wage scales, working hours, training, health and safety, overtime, grievance
mechanisms, and rights to participate in workplace or company affairs
Code of Ethics/business ethics
Ethical codes are adopted by organizations to assist members in understanding the difference between 'right' and 'wrong' and in applying that
understanding to their decisions
Bribery
Bribery is an act of giving money or gift giving that alters the behavior of the recipient. Bribery constitutes a crime and is defined by Black's
Law Dictionary as the offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or other person in
charge of a public or legal duty.
Due diligence:
"Due diligence" is a term used for a number of concepts, involving either an investigation of a business or person prior to signing a contract, or
an act with a certain standard of care.

It can be a legal obligation, but the term will more commonly apply to voluntary investigations. A common example of due diligence
in various industries is the process through which a potential acquirer evaluates a target company or its assets for an acquisition. The theory
behind due diligence holds that performing this type of investigation contributes significantly to informed decision making by enhancing the
amount and quality of information available to decision makers and by ensuring that this information is systematically used to deliberate in a
reflexive manner on the decision at hand and all its costs, benefits, and risks
Bid rigging
Is a form of fraud in which a commercial contract is promised to one party even though for the sake of appearance several other parties also
present a bid. This form of collusion is illegal in most countries. It is a form of price fixing and market allocation, often practiced where
contracts are determined by a call for bids.