Following is an open letter from the CCPA National Advisory Panel to the Association and its member companies:

The new principles recently announced by the Canadian Chemical Producers’ Association could herald a major step forward in the evolution of Responsible Care. The Responsible Care® Ethic & Principles for Sustainability broaden the scope of member company responsibilities and make it explicit that Responsible Care is the means by which the industry will progress toward sustainability. If effectively communicated, the new principles should make it clear to CCPA members and external stakeholders that Responsible Care and sustainability are now one and the same.

The National Advisory Panel generally endorses the new principles, although we are disappointed not to see an explicit reference to the precautionary principle. The real test for the future of Responsible Care will be how CCPA and its member companies interpret and implement the new principles. We want to see the principles interpreted in the spirit of Responsible Care and not just in terms of what is most convenient for member companies.

We understand that the principles will be implemented during the current Triennial (2008–2011) through changes in the Codes of Practice, guidance documents, verification and other processes. Implementation may also entail changing policies or, if deemed necessary, writing new policies.

The challenge for CCPA and its members will be achieving agreement on how the new principles should be interpreted and what changes will be needed to implement them. Related challenges include:

• Effective communication of the changes and their rationale to managers and line workers at all member companies and to the public
   
• Investing the resources needed for implementation
   
• Measuring the extent to which these changes affect industry actions and how those actions relate back to the principles.

In committing to the new principles, the Canadian chemical industry is presenting itself not only as a sector to be regulated and monitored, but as an integral part of the solution to problems that threaten the sustainability of the planet. This is a sea change in how the Canadian chemical industry understands itself and its role in the world. It is a change the National Advisory Panel welcomes.

In taking on this new role, and promising to revitalize Responsible Care, the industry is dramatically raising stakeholder expectations. It is therefore important that CCPA meet the implementation and assessment timetable it has set for itself (mid-2009 to the end of 2011) and communicate progress to stakeholders. Otherwise, CCPA and its members will be dismissed as all talk and no action.

We will be watching to see how the new principles are implemented and will continue to provide feedback and advice to the best of our ability.

About the Panel

Challenges from the Panel in response to the new Ethic & Principles:

The Panel is pleased to note that all of the long-term challenges we have presented to CCPA in the past have been captured in the new principles (see "Old Challenges and New Principles"), which will further drive the Association to strive to meet these challenges. We take this opportunity to issue some additional challenges:

Promote Responsible Care. We challenge CCPA to raise the profile of Responsible Care among suppliers and customers, and to introduce the Ethic to retailers, consumers, and other industry sectors.

National Leadership. At the national level, leadership means that CCPA will have to take progressive positions, for example on climate change, that differentiate it from other trade associations. Effective implementation of the new principles is the key to achieving that unique status.

International Leadership. We applaud the leadership shown by CCPA at the International Council of Chemical Associations and encourage the Association to continue to "punch above its weight." We also challenge member companies headquartered outside Canada to find ways to be leaders in their global structures. One way to do this would be to undertake leading-edge sustainability initiatives within Canada. Sometimes change in multinational companies is easier to start at the local or national level. Given its size and its similarities to both the U.S. and Europe, Canada is an excellent "laboratory" for demonstrating new ideas.

Educational Outreach. The good work that CCPA does in promoting Responsible Care to chemical engineering schools in Canada should be supplemented with efforts at the high school and elementary school levels. At a broader level, we urge CCPA to explore opportunities to work with other industries and government to support scientific literacy through the public education system.

Maintain the Reducing Emissions report. Along with external verification and community dialogue, this annual report on total current and projected emissions of CCPA member facilities is one of the key strengths of Responsible Care. It is an example of a core element of the Ethic: "to do the right thing, and be seen to do the right thing." The publication continues to generate industry dialogue with involved Canadians, enabling CCPA and its members to "be accountable and responsive to the public." We are concerned that CCPA may discontinue the report due to financial and resource challenges facing the Association. It is vital that, in spite of these challenges, CCPA seek ways to continue to publish Reducing Emissions on the Internet and in hard copies. We want to see the standard of disclosure established by the current data collection and production team maintained – including the emissions data, the overview of categories of emissions, and the informative essays on topics of current concern to the public.

Process Safety. The Panel finds the prospect of a loss of Canadian capacity in process safety management chilling, and urges the CCPA to take a leadership role in working with the Chemical Institute of Canada to find leadership partners and permanent core funding for a Process Safety Management Institute.

Advancing Legal Requirements. The Panel notes that CCPA has documented the absence of federal or provincial legislative requirements addressing existing elements of the Responsible Care Codes of Practice. In line with its new ethic, CCPA should seek to have code requirements enacted into law.

Public Dialogue. The Reducing Emissions report, public availability of verification reports, the National Advisory Panel, other stakeholder consultation processes, and community dialogue processes continue to make CCPA a leader in public dialogue and accountability. We challenge CCPA to take one step further in dialogue with the general public by instituting an interactive comment page on the Association website, enabling members of the public to speak directly to the CCPA.


Old Challenges and New Principles
Long-term challenges previously set by the Panel are captured, at least implicitly, in the new ethic and principles:
 

CCPA National Advisory Panel: Current Members

QUEBEC

Mark Goldberg
Epidemiologist involved in occupational and environmental health problems. Associate Professor in the Department of Medicine and Associate Member in the departments of Occupational Health, Epidemiology & Biostatistics, and Oncology, McGill University. Currently working on the relationship of breast cancer in women and exposure to toxic substances in the workplace and the effects of air pollution on human health.

Richard Janda
Professor at Faculty of Law, McGill University. Member, the McGill School of Environment. Hydro Québec Scholar in Sustainable Development Law, and a Senior Research Fellow at the Centre for International Sustainable Development Law.

Bruce Walker
Montreal environmental activist. Works on air and sewage issues on behalf of STOP, a citizens’ environmental group. In 2004, recipient of a Canadian Environmental Award for his work on air quality. Sits on several community advisory panels in Montreal. Has participated in two external Responsible Care verifications (Solutia and Pétromont).

ONTARIO

Kevin Auty
Director of Asset Protection for Home Depot Canada and Asia. Responsible for The Home Depot's leadership position in Environmental Stewardship, Health, Safety, Disability Management, Operational Profit Protection and Loss Prevention.

Brian Kohler (recently resigned from Panel as he has assumed an international union position in Europe) National Representative – Health, Safety and Environment at the Communications, Energy and Paperworkers Union of Canada (CEP), which includes many chemical workers.

Gail Krantzberg
Professor and Director of the Dofasco Centre for Engineering and Public Policy in the School of Engineering at McMaster University. Completed M.Sc. and Ph.D. at the University of Toronto in environmental science and freshwaters. Worked for the Ontario Ministry of Environment from 1988 to 2001 on Great Lakes Programs and was the Director of the Great Lakes Regional Office of the International Joint Commission from 2001 to 2005. Has authored more than 100 scientific and policy articles on issues pertaining to ecosystem quality and sustainability.

Debra Krukowski
Founder and member of Sarnia Transportation Community Advisory Panel for CCPA Partner Companies Harmac, Procor, CN, GATX and Marcus; Chairperson of Inter-Recycling Landfill Liaison Committee; Chairperson of Sarnia Planning Advisory Committee; Member of Property Standards Committee for City of Sarnia.

Robin Moore-Orr
Adjunct Associate Professor in the Division of Community Medicine in the Faculty of Medicine at Memorial University of Newfoundland. Vice-Chair of the Board of the Canadian Institute of Child Health. Holds a doctorate in Nutrition and Health Services Administration from the Harvard School of Public Health.

Ken Ogilvie
Environmental consultant and a member of many boards and advisory committees to government, industry and not-for-profit groups. Served for many years as executive director of Pollution Probe, one of Canada’s prominent environmental organizations. Holds a BSc in civil engineering from the University of Waterloo and an MBA from York University.

Ron Ormson
Director of Environmental Engineering for the City of Waterloo. Part-time faculty member in the post-graduate Environmental Engineering Technology Program at Conestoga College, Kitchener. Member of the Chemtura Public Advisory Committee, Elmira, Ontario since 1998. Areas of interest include contaminated site remediation and air emissions control.

Edwin Tam
Associate Professor in civil and environmental engineering at University of Windsor. Participates as a public representative in ongoing MOU discussions between the federal government and CCPA on voluntary environmental initiatives. Research and teaching interests include sustainability and engineering, product recovery, and environmental management. Holds a Ph.D. in Environmental Engineering from the University of Toronto.

Jim Wakefield
Founding member of the West Hill Community Advisory Panel. Participated as verifier in Responsible Care Verifications as local community member and presently as member of the broader public. Retired from Bell Canada, where he managed accounting and planning functions, including Contingency Planning/Emergency Response. Holds a Bachelor of Commerce from Concordia University.


ALBERTA

Cindy Jardine
Associate Professor in the Department of Rural Economy at the University of Alberta. Past experience in environmental water quality and pollution control with various provincial government and international agencies. Current research interests and activities involve environmental health risk assessment, risk communication and different perspectives on risk.

Keith Purves
Chairs the Fort Air Partnership, an air monitoring society in the Fort Saskatchewan region. Was a Responsible Care verifier (public member) at two chemical companies in the area.