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Third Party Verification

NACD's Responsible Distribution ProcessSM requires two separate third-party verification processes that are conducted by independent third-party verification firms designated by NACD:

Document Verification (see information below)
Responsible Distribution Verification (on-site verification)

Document Verification (4th Cycle, 2010-2012)

The purpose of the Responsible Distribution Document Verification is to review documented policies and procedures for NACD's Responsible Distribution for all NACD Candidate members and Chemical Handler Affiliates (CHAs). The Document Verification will include:

Document Verification contract and payment
Company Profile Questionnaire: Provides a written overview of the company's operations, management structure, product lines, etc.
Self Assessment Report: Determines if the company has reached Stage V on all applicable elements of the Responsible Distribution Code of Management Practice.
Documented Responsible Distribution policies and procedures for requested codes, demonstrating consistency with the spirit and intent of the Code of Management Practice and/or are representative of the functions and facility usage described in the company profile. A sample of each of four (4) sections selected will always include at least one (1) of the following Core Codes:
- Compliance Review and Training
- Handling and Storage
- Job Procedures and Training
- Emergency Response and Public Preparedness

and will also include (3) randomly selected sections of the Code of Management Practice.

NACD Candidates and CHAs mail their required documents to the designated third party verifier.

Process Timeline for Responsible Distribution Document Verification

Calendar Days (following the items indicated above)	Activity
30	The verifying firm completes review of Company Profile, Self-Assessment Report, and requested Responsible Distribution policies and procedures.
35	The verifying firm recommends NACD Candidate or CHA for a verification “pass” and notifies NACD OR the verifying firm notifies applicant with a request for additional documentation or corrective action recommendation (applicant has 30 calendar days to submit additional documentation to verifying firm).
65	Last day for NACD Candidate or CHA to submit additional documentation that was requested (if previously indicated by verifying firm).
75	The verifying firm completes review of additional documentation (if indicated by verifying firm) that was requested, verifies resolution of request or corrective action recommendation, or issues a failed verification (and informs NACD). The verifying firm issues Document Verification certificate to applicant and copies NACD on status.

Note: 'Calendar Days' represent the last day on which these requirements can be met.

Document Verification -Third Party Verifiers (2010-2012)

Each applicable Candidate and Chemical Handler Affiliate will enter into a contractual agreement directly with one of the verifying firms, assigned by NACD, below that will identify payment terms and specifics regarding confidentiality and indemnification. All costs associated with the compliance verification process will be the sole responsibility of each member company as outlined in the contract.

The cost for the initial review will be $660. A member company will incur an additional charge for re-evaluation if it is found to be non-compliant after the initial review and sixty-day period of corrective action.

Compliance Solutions Group
Primary Contact: Michael Loolara
16851 Jefferson Hwy, Suite 6D
Baton Rouge, LA 70817
225/754-0405
Fax: 225/754-0406
mloolara@compliance-sg.com

Eagle Group USA
Primary Contact: Deborah Iafrate
6001 North Adams Rd, Suite 250
Bloomfield Hills, MI 48304
248/355-4421
Fax: 248/355-4623
Deborah.Iafrate@eaglegroupusa.com