1 european awards 2010 1 f. marcenac, ph. gagnaire, dr b. despres, o lemarie, a leplay, m...
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European Awards 2010
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F. MARCENAC, Ph. GAGNAIRE, Dr B. DESPRES, O LEMARIE, A LEPLAY, M CROZIER-PATOUX
Responsible Care®European Awards 2010
CMR risk managementCMR risk management
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RHODIA IN BRIEF
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● International chemical company with leading position in all core activities● Well-balanced presence worldwide● Wide variety of markets served
Chemistry is our world
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● Group which combines innovation and responsibility in business activities
● - a framework of commitments deployed throughout the Group
● Performance recognized by Rhodia's inclusion in the
Responsibility is our way
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55
20% turnover
EBITDA(1)
487€ million
Sales
4.011€ billion
Production sites
64Employees
13,850
Operating income
160€ million
New products launched in past 5 years
* Following reclassification of activities which have been or are in the process of being disposed of(1) Recurring EBITDA: before restructuring costs and other operating income and expenditure
Key figures for 2009*
world-wide
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Global presence
20% of sales35% of sales
28% of sales
45% of sales in regions with strong potential for growth
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North AmericaSales: €802 million1,600 employees
EuropeSales: €1.404 billion6,000 employees
Latin AmericaSales: €682 million
2,900 employees
17% of sales
Asia PacificSales: €1.123 billion3,100 employees
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Number 3
Ranking in key business areas
• High-performance silicasHigh-performance silicas
• Rare earthsRare earths
• Diphenols for vanillinDiphenols for vanillin
• Specialty surfactants and Specialty surfactants and polymerspolymers
• GuarGuar and derivatives and derivatives
• Sulphuric acid regeneration*Sulphuric acid regeneration*
• CO2 emission credits (CERs)CO2 emission credits (CERs)
Sources: RHODIA estimates
• CelluloseCelluloseacetate towacetate tow
• Polyamide 6.6Polyamide 6.6• Engineering Engineering
plastics based on plastics based on polyamide 6.6polyamide 6.6
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Number 1 Number 2
* USA
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Responsibility rooted in Rhodia's culture
• Responsibility - the cornerstone of Rhodia Group culture
• Pioneer in commitment to Sustainable Development. Joined Responsible Care initiative back in 1985
• One of the world's best records in occupational safety• Rhodia Way: continuous improvement framework based on commitments to our stakeholders
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Rhodia's Management BookThe Management Book is designed to provide all Group employees with a framework for conducting their activities. It incorporates Rhodia's commitment to Sustainable Development and ensures compliance with the levels of corporate governance expected from a listed company. The Management Book embodies four objectives:
• Simplify and standardize common language and rules for the entire Group
• Strengthen managerial performanceThe Management Book describes methods which operate Group-wide. The 12 processes defined in the book are structured to maximize the effectiveness of teams by defining responsibilities and standardizing working processes. The Management Book also sets out the management rules which form the point of reference for the good practices which all managers must apply. Application of these rules strengthens discipline and aligns practices at each level of the Group's structure and is a key factor in efficiency.
• Provide clarityThe Management Book indicates who decides what and describes the 12 key processes which underpin the Rhodia organization.
• Controlling risks by an effective internal control systemEach individual responsible for a process must identify the risks associated with the practice of his/her activities, assess the severity of these risks and set the means in place to monitor and control them. The Management Book indicates the "Red Lines" which must be observed by all and which may incur severe penalties if they are crossed.
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Management of risks associated with CMR* substances: a major concern
• Management Book Red Lines
• What Rhodia defines as a CMR substance
• Scope of application
• List and track
• Status in 2009
• What needs to be done next
* Substances classed as Carcinogenic, Mutagenic or toxic for Reproduction
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CMR: a Management Book Red Line
• The red line relating to CMR substances is mandatory for all Group entities.
A thorough review must be conducted within three years of the A thorough review must be conducted within three years of the identification of a CMR substance, with the aim of eliminating identification of a CMR substance, with the aim of eliminating the substance or controlling the risk if the substance cannot be the substance or controlling the risk if the substance cannot be eliminated.eliminated.
The CMR red line means applying the principle which operates in Europe under the REACH regulations which requires authorization and seeking to identify substitutes for CMR SVHCs (substances of very high concern) on all sites where Rhodia operates world-wide.
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What Rhodia defines as a CMR substance
Step 1: Definition of criteria which can be adopted by a Group whose products are used throughout the world.
• Diversity of regulations in force in the countries where the group operates
=> need for a single CMR reference
• Establish definition of a CMR at group level:
• Substance which meets the criteria for classification as a category 1 or 2 CMR substance as defined in Annex VI of Directive 67/548/EEC (including substances which are self-classified by Rhodia or by another supplier).,
• Substance which meets the criteria for classification as a Group 1 carcinogen (carcinogenic for humans) or Group 2A carcinogen (probably carcinogenic for humans) according to the IARC classification system
• Substance or preparation containing one or more substances classed as CMR applying the criteria indicated above at a concentration equal to or greater than the concentration limits specified in the regulations.
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Control process on Rhodia sites Control process on Rhodia sites Flowchart for assessment of risks of Flowchart for assessment of risks of exposure to CMR substances exposure to CMR substances
Exhaustive and rigorous procedure for the assessment and control of CMR substance risks
applying the principles contained in Rhodia's integrated HIRA (Hazard applying the principles contained in Rhodia's integrated HIRA (Hazard Identification and Risk Assessment) management system.Identification and Risk Assessment) management system.
Recherche de CMR R45, R46, R49, R60 ou R 61
IARC groupe 1 ou 2A
Recherche de CMR R45, R46, R49, R60 ou R 61
IARC groupe 1 ou 2A
InventaireInventaire
Présence de CMR
Le site n'est plus concerné sauf gestion du passé
Le site n'est plus concerné sauf gestion du passé
SubstitutionPossible ?
Le site n'est pas concerné sauf si CMR présents antérieurement
Le site n'est pas concerné sauf si CMR présents antérieurement
Évaluation des possibilités d'exposition
Évaluation des possibilités d'exposition
Substitution made
NO
YES
Not possible
FormationinformationFormation
information
Recherche de CMR R45, R46, R49, R60 ou R 61
IARC groupe 1 ou 2A
Identify CMR substancesR45, R46, R49, R60 or R 61
IARC group 1 or 2A
InventaireInventory
CMR substancepresent
Le site n'est plus concerné sauf gestion du passé
Site only included for managing pastsituation
Substitutionpossible ?
Le site n'est pas concerné sauf si CMR présents antérieurement
Site not includedunless CMRmaterial presentpreviously
Évaluation des possibilités d'exposition
Assessment of possibilityof exposure
Substitution
N
Formationinformation
TrainingInformation
Évaluation des possibilités d'expositionÉvaluation des possibilités d'exposition
Les possibilités d'expositionpeuvent-elles être exclues
de façon certaine ?
Évaluation approfondie
Risque d'exposition
Risque acceptableEnregistrement et Archivage Maintenir la situation sous
contrôle
Risque acceptableEnregistrement et Archivage Maintenir la situation sous
contrôle
Situationaméliorable / Indésirable
Situationaméliorable / Indésirable
Liste des personnes exposées•Réduction des expositions immédiasi situation indésirable•Plan d'action si situation améliorabl
Enregistrement donnéArchivage
Enregistrement donnArchivage
YES
NO
Exemple : confinement total re-assessment
YES
NO
Évaluation des possibilités d'expositionAssessment of possibility of exposure
Can the possibilitiesof exposure be eliminated -
completely?
In-depth assessment
Exposure risk
Risque acceptableEnregistrement et Archivage Maintenir la situation sous
contrôle
Acceptable risk Record and hold on fileKeep situation under
control
Situationaméliorable / Indésirable
Unsatifactory /Scope for improvement
List of persons exposed•Reduction of immediate exposureif situation unsatisfactory•Action plan if can be improved
Enregistrement donéeArchivage
Record dataFile
e.g. total containment
Regular
N
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Reagents used in testing and
R&D laboratories
Raw materials
Intermediates
Processing aids
Wastes
Marketed products
R&D centres Production sites
Production sites Marketing & Sales
Possible presence of CMR substances in value chain
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• Substance type • Raw material
• Isolated intermediate
• Non-isolated intermediate
• Finished product
• Waste
• Other products, such as solvents and reagents used in laboratories, or products used in maintenance work
• Activities examined• Process
• Research and Development: Laboratory and pilot unit
• Quality control: laboratory
• Maintenance
• Framework procedures• Management of risks associated with CMR substances
• Management of risks in the workplace associated with the use of CMR substances
• Management of risks for marketed CMR substances
Scope and framework procedure for CMR risk management
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• Target set in 2007: 100% of dossiers produced by end December 2009, including new CMRs introduced by the 30th and 31st ATPs*.
• Dossiers are not closed until all stages in their preparation have been completed • Number of CMR substances used
• Number of activities using the CMR substances
• Substitution or non-substitution briefing documents drafted (%)
• Number of risk assessments performed (%)
• Number of dossiers finalized (%)
• Management tools• Inventory of all substances used and manufactured on all of the Group's sites
(updated every 2 years)
• Quarterly report for monitoring application of red line as closely as possible
• This ensures that each site is kept informed of progress on the CMR dossier relating to it
CMR dossier and management tools
* Adaptations to Technical Progress of Directive 67/548/EEC
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• Out of the 1,500 substances used or marketed by Rhodia, seven marketed substances have a CMR risk associated with them. The annual volume of these substances is below 10,000 tonnes.
Action taken• 21 substances were identified as being CMR substances in 2007• Solutions involving substitution or halting marketing were identified for 14 substances • Production of certain substances was stopped, e.g. in France (acrylonitrile line) and in China (solvent
containing dimethylformamide)
• Products used on Rhodia sites: of the 140 CMR substances employed for less than 650 uses, 32 substances are used in quantities exceeding 100 kg/year and 10 raw materials alone account for an annual volume of almost 400,000 tonnes
Action taken
• Diatomaceous earth (CMR substance) replaced by perlite as filter medium on many sites.
• Change from fuel oil (CMR substance) to gas, also bringing reduction in CO2 emissions.
• Discontinuation of use of certain substances which are carcinogenic by inhalation in powdered form (cobalt sulphate, bichromates) and replacement with other solutions
• Elimination of unused CMR substances stored in laboratories
• Position in December 2009• 99% of risk assessments completed
• 98% of substitution or non-substitution briefing documents drafted
• 97% of CMR dossiers finalized, with target of 100% for end 2009
The total figure is around 1,000 dossiers.
Position at end 2009
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Initiatives undertaken by multi-disciplinary teams
Initiatives took the form of mini-projects with staff from the different entities concerned pooling their expertise and resources, i.e.:
• Health, Safety and Environment (HSE)
• Responsible Care Department's expertise in toxicology
• Responsible Care Department's regulatory intelligence
• Site and regional Occupational Health functions
• R&D
• Site analytical testing functions,
• Product Stewardship
• Site production and maintenance departments,
• Process managers,
• Business unit production management functions
• Responsible Care status reporting.
Staff have conducted studies on all CMR substances concerned at Rhodia sites
FinishedFinished products (<10 kt/yr)products (<10 kt/yr)Raw materials & Raw materials & intermediates (≈ 400 kt/yr)intermediates (≈ 400 kt/yr)
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What needs to be done next
Complete all action plans already decided, plus:
• CMR substances produced and marketed by Rhodia• Employ the R&D process to challenge the use of CMR substances by initiating research
into alternative processes
• Work with our customers to look for substitutes and examining risk control for the CMR substances they use - this approach was first adopted in 2008
• Raw materials and reagents used on Rhodia SITES• Use solutions at concentrations which are below the CMR classification limits for
preparations.
• Continue investigations into substitute catalysts
• Contribution to reducing environmental impact (example)• Remediation of brown field sites: Scheduled investment for bio-remediation of leachate
on a waste site containing chromium VI using bacteria to convert this CMR substance into chromium III (a non-CMR substance)
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APPENDICES
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Summary of progress in creating CMR dossiers
• Almost 650 uses of CMR substances recorded
• For 140 CMR substances
(1) 30th and 31st ATPs included.
*
(1) (1)HEALTH & SAFETY RISK ANALYSIS2005 2006 2007 2008 (1) 2009 (1)
Number of uses of CMR substances on our sites (categories CE 1, 2, IARC 1 and 2a)
- 607 510 540 637
Number of activities concerned - 720 740 862 1 084
Substitution or non-substitution briefing documents drafted (%)
- 25% 67% 98% 98%
In-depth risk assessments performed (%) - 27% 68% 98% 99%
CMR dossiers completed (%) - 24% 63% 98% 97%
Current scope (2009)
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CMR - Quarterly report Q4 2009
Rhodia Group
Eco Services
Silcea Novecare Polyamide Research AcetowEnergy Services
SBU Salicyliques & Fluores
Q4 2006 * 25% 0% 3% 50% 7% 79% 0% 7%
Q4 2007 * 64% 21% 62% 43% 81% 87% 86% 59%
Q4 2008 ** 98% 86% 98% 100% 98% 98% 97% 22% 100%
Q1 2009 ** 92% 100% 86% 89% 95% 98% 97% 22% 93%
Q2 2009 ** 92% 100% 86% 90% 92% 99% 96% 22% 93%
Q3 2009 ** 94% 100% 96% 90% 93% 100% 96% 22% 93%
Q4 2009 ** 97% 100% 96% 99% 89% 100% 96% 100% 100%
Q4 2009 target 100% 100% 100% 100% 100% 100% 100% 100% 100%* data published at the end of year 2006, 2007 or 2008
** taking in account 30 & 31 ATP
Information issued to all personnel every three months and to stakeholders annually (Technical Sustainable Development report)
Consolidated CMR status worldwide
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97%
100%
96%
99%
89%
100%
96%
100%
100%
82% 84% 86% 88% 90% 92% 94% 96% 98% 100%
Rhodia Group
Eco Services
Silcea
Novecare
Polyamide
Research
Acetow
Energy Services
SBU Salicyliques & Fluores
97%
99%
99%
89%
98%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Rhodia Group
Europe
North America
South America
Asia Pacific
By Business UnitBy Business Unit
By geographic regionBy geographic region
Effective operational control through consolidation and progress reporting
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Classification of 140 CMR raw materials used by Rhodia*
CMRCMR Quantities used Quantities used annually (tonnes)annually (tonnes)
Number of sites where Number of sites where CMR substances are usedCMR substances are used
1-3 Butadiene1-3 Butadiene Confidential Confidential 33
Ethylene oxideEthylene oxide ConfidentialConfidential 88
Propylene oxidePropylene oxide ConfidentialConfidential 77
1.2-Dichloroethane1.2-Dichloroethane ConfidentialConfidential 44
FormaldehydeFormaldehyde ConfidentialConfidential 1616
2-(2-Aminoethylamino) ethanol (new 2-(2-Aminoethylamino) ethanol (new entry in 2008) entry in 2008) ConfidentialConfidential 11
ParaformaldehydeParaformaldehyde ConfidentialConfidential 11
EpichlorohydrinEpichlorohydrin ConfidentialConfidential 44
Benzyl chlorideBenzyl chloride ConfidentialConfidential 33
Diethyl sulphateDiethyl sulphate ConfidentialConfidential 66
• 32 CMR substances are used in significant volumes (> 100 kg/ yr) 32 CMR substances are used in significant volumes (> 100 kg/ yr)
• Top 10 significant users account for 94% of CMR substances usedTop 10 significant users account for 94% of CMR substances used
* 2008 data