Code of Management Practice

I. Risk Management  |  II. Compliance Review and Training  | III. Carrier Selection  | IV. Handling and Storage | V. Job Procedures and Training  | VI. Waste Management  |  VII. Emergency Response and Public Preparedness |  VIII. Community Outreach |  IX. Product Stewardship  |  X. Internal RDP Audits  |  XI. RDP Corrective and Preventive Action  | XII. RDP Document and Data Control 

New Code Requirements, Effective 05/01/06 (new requirements in red text):

Download the RDP Guiding Principles & Code of Management Practice

Each member company shall have an active program designed to continuously improve safety and reduce incidents. This Code does not impose upon member companies any obligation to guarantee compliance by third parties, i.e., parties over whom the member companies have no control. This program shall include:

I. Risk Management

1. Senior management commitment, through policy, communications, and resources, to on-going improvements in chemical distribution safety.
2. Regular review with suppliers of the hazards of materials.
3. Identification and implementation of risk reduction measures.

II. Compliance Review and Training

1. A process for monitoring regulations and industry practices for their application to chemical distribution activities.
2. A process for implementing applicable regulations and industry practices that apply to chemical distribution activities.
3. Training for all employees in the implementation of applicable regulations, as well as member company’s specific requirements.
4. A process for review of employee compliance with applicable regulations and member company’s specific requirements and review of outside contractor and re-seller compliance with member company's specific requirements.

III. Carrier Selection

1. A process for selecting carriers to transport chemicals that includes carrier safety and fitness, security, regulatory compliance, and performance review.

IV. Handling and Storage

1. Procedures for ensuring that containers are appropriate for the chemical being shipped, comply with regulatory requirements, and are free from leaks and visible defects.
2. Criteria for the cleaning and re-use of transportation equipment and chemical containers, and the proper disposal of cleaning residues.
3. Procedures for loading and unloading chemicals at member company’s facilities that result in protection of personnel, a reduction in emissions to the environment, and an increased awareness of hazards from inadvertent mixing of incompatible chemicals.
4. A process for providing manufacturer guidance and information to customers, warehouses, terminals, and carriers on procedures for loading, unloading, and storing chemicals; and a process to increase awareness of hazards from inadvertent mixing of incompatible chemicals."
5. A process for selecting owned and contracted facilities and sites for chemical storage or handling that emphasizes safety, fitness and includes reviews.
6. Documentation of current operating procedures for handling and storing chemicals.
7. Facility design, construction, maintenance, inspection, and security practices that promote facility integrity, consistent with recognized codes and regulations
8. Develop a process for addressing chemical site and chemical transportation security, to include conducting a security vulnerability assessment.
9. Provisions for control of processes and equipment during emergencies resulting from natural events, utility disruptions, and other external conditions.
10. Procedures to properly label and mark packages and containers.

V. Job Procedures and Training

1. Identification of the skills and knowledge necessary to perform each job.
2. Establishment of procedures and work practices for safe operating and maintenance activities.
3. Training for all personnel, to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job, including confirmation of competence.
4. Programs designed to assure that personnel in safety critical jobs are fit for duty and are not comprised by external influences, including alcohol and drug abuse.
5. Outside Contractors: In areas where hazardous materials are present, members shall have a process in place to inform contractors of the known hazards and the emergency action plan.

VI. Waste Management and Conservation Practices

1. Procedures to ensure that all self-generated waste and empty containers are disposed of in a responsible manner, and in accordance with existing regulations.
2. A clear commitment by senior management through policy communications, resources, and programs to ongoing waste reductions and pollution prevention at each member facility.
3. A commitment to institute resource conservation measures.

VII.Emergency Response and Public Preparedness

1. A process for responding to, reporting on, and investigating chemical distribution incidents and releases involving the member company’s chemicals, and implementation of appropriate preventive measures developed from that investigative process.
2. A system of internal investigation, reporting, appropriate corrective action, and follow-up for each incident and/or near miss that result or could have resulted in chemical incidents or releases.
3. Procedures for making emergency response information concerning the member company’s chemicals available to response agencies.
4. Communication with state and/or local emergency planning commissions and response organizations on the potential hazards of the member company’s chemicals.
5. Annual review, testing, and assessment of the operability of the member company's written emergency action and fire prevention plan and/or emergency response plan.
6. Facility tours for first responders to promote emergency preparedness and to provide current knowledge of facility operations.
7. Coordination of the written facility emergency response plan with the local emergency response team and other facilities. If no community plan exists, the facility should assist with efforts to create one.
8. Participation in the Local Emergency Planning Committee’s process to develop and periodically test the local emergency response plan.

VIII. Community Outreach

1. Interaction with organizations, associations, government officials and/or the public on behalf of NACD’s Responsible Distribution ProcessSM.
2. Information and updates for employees on the Responsible Distribution ProcessSM to encourage key employees to become involved in community outreach efforts.
3. Advocacy of responsible public policies and regulations for chemical distribution.

IX. Product Stewardship

Customers

1. A process to qualify customers as prescribed by governmental regulation.
2. Member companies should work with customers to foster appropriate dissemination of information on the proper use, handling and disposal of products commensurate with product risk. A member may decide to cease doing business with customers whose practices are clearly inconsistent with the Responsible Distribution ProcessSM.

X. Internal RDP Audits

1. Member companies shall establish documented procedures for regularly scheduled INTERNAL AUDITS to verify the implementation of policies and procedures supporting the RDP Code of Management Practice. The audits will be used to evaluate the effectiveness of the policies and procedures. Internal Audits shall be done on a yearly basis beginning with successful completion of the Interim Verification Process.
2. Audits shall be recorded and results brought to the attention of appropriate management personnel who must take timely corrective or preventive action. Annual audit results should be retained until the next Third-party On-Site Verification is completed.

XI. RDP Corrective and Preventive Action

1. Member companies shall establish a CORRECTIVE AND PREVENTIVE ACTION system for RDP related issues. This system should permit the identification and communication of inadequacies or improvements in each member company's implementation of RDP.
2. Member companies shall establish and maintain procedures for implementing corrective action and preventive actions arising from internal and external audits or other sources. Any corrective or preventive action taken to resolve the cause or RDP implementation inadequacy shall be appropriate, as determined by member company management, to the magnitude of the cause or inadequacy and commensurate with the risk involved.

XII. RDP Document and Data Control

1. Member companies shall establish and maintain a documented system to control all policies and procedures supporting RDP. In addition, member companies shall maintain a documented system to control the documents and data relating to RDP itself as issued by the National Association of Chemical Distributors (NACD).
2. Data includes any of the above that is electronically stored and utilized.
3. These documented procedures shall include provisions for review and approval of any new or revised policies and procedures by the authorized personnel within the member company.

4. A master list or functionally equivalent document control system identifying the current version of each document shall be established and be readily available to preclude the use of invalid and/or obsolete documents. The system shall ensure that:

   Changes to documents and data shall be reviewed and approved by the same function/organization that performed the original review and approval, unless specifically designated otherwise. These functions/organizations shall have access to pertinent background information upon which to base their review and approval. Where practical, the nature of the change shall be identified in the document or appropriate attachments.

Updated: 5/2006; Effective May 1, 2006