88.1.1Manufacturing facility programs
Each sodium cyanide manufacturing facility operates under legal constraints and obligations from a variety of local, state and Commonwealth government legislation and the chemical industry. These include the Responsible Care® program (refer below) and various Codes of Practice for chemical storage, handling, transport (e.g. ADG Code, IMDG Code). In addition, each manufacturing facility has established Environmental Management Systems (EMS; or equivalent environmental safety systems), and a Quality Management System (e.g. ISO9001, ISO14000).
The manufacturing industry operates with a ‘cradle to grave’ approach to sodium cyanide products, which means that responsibility for sodium cyanide product is broadened beyond the manufacturing facility operations to cover use and appropriate waste management.
Other manufacturing industry initiatives include:
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Safety Management Systems, emergency procedures, and guidance documents for the safe handling of sodium cyanide products (e.g. Ticor, 2000);
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Transport Management Plans for sodium cyanide;
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Controlled document systems for operational and administrative systems and procedures; and
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Safety Data Sheets and emergency procedure guidance.
88.1.2Responsible Care® program
The Responsible Care® program is an initiative of the international chemical industry to improve the health, safety and environmental performance of its operations and to increase community involvement and awareness of the industry. It was introduced in September 1989. Australia was the third country to join, and approximately 46 countries currently participate in the Responsible Care® program (PACIA, 2002).
Adherence to Responsible Care® is a condition of membership of the Australian industry’s peak body, the Plastics and Chemicals Industries Association, Inc. (PACIA), for companies manufacturing, importing and distributing chemicals in Australia. Each of the major sodium cyanide manufacturers in Australia is a member of PACIA.
The Responsible Care® program operates under guiding principles that include operational safety, product stewardship, resource sustainability, community involvement, industry collaboration, and co-operation with government. Six Codes of Practice define the performance practices required for PACIA member company operations and products. These Codes of Practice complement existing legal requirements and require co-operative action with the community.
Codes of Practice include:
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Product Stewardship: Product Stewardship is the responsible and ethical design and management of products throughout the entire product life cycle, in order to ensure health and safety and protect the environment. It is a demonstrable process that places an ongoing responsibility on a company to identify, monitor, manage and continually improve the health, safety and environment performance of its products and packaging. The purpose of product stewardship and of the associated Code of Practice is for a company to actively engage in the identification and management of the risks associated with its products, to the extent consistent with its degree of influence at each stage of the product life cycle. It covers member company actions necessary to fulfil the Guiding Principles of Responsible Care®.
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Community Right to Know: This Code governs member company action regarding Community Right to Know, particularly in order to fulfil the Guiding Principle of Responsible Care®. This Code is intended to result in member companies responding to community concerns about their activities by providing mechanisms for community consultation on processes and products and by providing extensive information in a simplified, readily accessible way. The level of effort will be proportionate to the inherent risk and the degree of community concern.
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Environment Protection: This Code governs member company actions regarding management of the environmental aspects of their activities, conservation of resources and reduction of waste in order to fulfil the Guiding Principles of Responsible Care®. In general, implementation of this Code will reduce the burden of member company activities on the environment and contribute towards industry sustainability.
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Manufacturing Process Safety: This Code governs member company actions regarding safety of chemical manufacturing processes. This Code provides guidance as well as a means to measure continual improvement in the management of process safety in manufacturing.
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Employee Health and Safety: This Code governs member company action regarding health and safety of people involved in operational activities, particularly in order to fulfil the Guiding Principle of Responsible Care®. It is recognised that education / training of employees and prevention of incidents is fundamental to the achievement of the purpose of this Code. Prevention only occurs when there is a conscious systematic effort to make it happen.
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Storage and Transport Safety: This Code governs member company actions regarding storage and transport consistent with the Guiding Principles of the Responsible Care®. In general, the implementation of this Code involves setting management plans and objectives, carrying out hazard evaluations, implementing risk reduction programs, prompt and effective emergency response and supporting a community awareness program. With these in place, the member companies and PACIA will be able to quantitatively measure performance on safety associated with storage and transport activities. PACIA provide an accreditation scheme for carriers of dangerous goods in Australia. Chemical and transport industry representatives developed the PACIA Carrier Accreditation Scheme. This industry-regulated scheme aims to measurably improve the safety performance of transport carriers for the chemical industry by introducing an integrated, national standard of performance auditing. This will have the effect of streamlining the implementation of the audit requirements of the Responsible Care® Transportation Code of Practice, whilst minimising duplication and audit costs.
PACIA notes that many companies have tailored quality, environment and safety systems such as ISO 9001 and ISO 14001 and that implementing equivalent elements from those systems would meet the requirements of the PACIA Codes of Practice.
In response to international environmental incidents involving cyanide, the major Australian sodium cyanide manufacturers undertook a review of the Australian situation. This led to the development of a working party of the major manufacturers as a Responsible Care® program initiative (PACIA, 2000).
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