The American Chemistry Council (ACC): Alliance Agreement

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AGREEMENT ESTABLISHING AN ALLIANCE
BETWEEN
THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
U.S. DEPARTMENT OF LABOR
AND
THE AMERICAN CHEMISTRY COUNCIL

The Occupational Safety and Health Administration (OSHA) and The American Chemistry Council (ACC) recognize the value of establishing a collaborative relationship to foster safer and more healthful American workplaces. OSHA and the ACC hereby form an Alliance to provide OSHA, the ACC's members and ACC's Responsible Care® Partners, and others with information, guidance, and access to training resources that will help them protect employees' health and safety, particularly through matters of mutual interest in promoting high levels of safety and health performance and improved dialogue through the OSHA Voluntary Protection Programs and ACC's Responsible Care Initiative.

OSHA's Voluntary Protection Programs (VPP) promotes effective worksite-based safety and health. In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that have implemented a comprehensive, performance-based safety and health management system. Approval into VPP is OSHA's official recognition of the outstanding efforts of employers and employees who have achieved exemplary occupational safety and health.

Responsible Care is ACC's signature environmental, health, safety, and security performance improvement initiative that extends continuous improvement efforts beyond the facility fence line to include the entire value chain. ACC member companies and Responsible Care Partner companies are required to adhere to the Responsible Care program, which includes third-party certification of a company-wide environmental, health, safety, and security management system [Responsible Care Management System® (RCMS®) or RC14001 (joint Responsible Care and ISO 14000 program)] and comprehensive, publicly reported performance measurements.

In developing this Alliance, OSHA and the ACC recognize that OSHA's State Plan and Consultation Project partners are an integral part of the OSHA national effort, and are supportive of the FY2006 Strategic Plan by acquiring and disseminating information to new audiences.

OSHA and the ACC will work together to achieve the following training and education goals:

Work with OSHA to provide expertise to develop training and education programs for participants in Responsible Care® and VPP, regarding the similarities and differences in the two programs and to provide expertise in communicating such information to individuals interested in applying for either program.
Work with OSHA to provide expertise in the development of training and education programs for VPP evaluators (including VPP Regional staff) and Responsible Care auditors, regarding the similarities and differences in the two programs and communicate such information to appropriate individuals.

OSHA and the ACC will work together to achieve the following communication and outreach goals:

Work with OSHA to provide expertise in developing information which will continue to promote the goals of this Alliance.
Speak, exhibit or appear at OSHA's VPP or ACC's Responsible Care conferences, meetings or sponsored events regarding the similarities and differences between each program to encourage participation.
Share information among OSHA personnel, ACC members and Responsible Care Partners, and other industry safety and health professionals regarding VPP and ACC's Responsible Care best practices.
Publicize areas of consistency between VPP and Responsible Care by utilizing the gap analysis tools noted in Appendix A.

OSHA and the ACC will work together to achieve the following goal related to promoting the national dialogue on workplace safety and health:

Develop means to publicize the results achieved by companies that are joint participants in Responsible Care and VPP.

OSHA and ACC will continue to work with the synergies between the two programs in order to leverage resources and work on the continued goals of safety and health. Some examples include:

Identifying opportunities for Responsible Care participants to be considered for VPP Corporate status.
Examining different ways to coordinate VPP evaluations and Responsible Care® audits.

OSHA's Alliances provide parties an opportunity to participate in a voluntary cooperative relationship with OSHA for purposes such as training and education, outreach and communication, and promoting a national dialogue on workplace safety and health. These Alliances have proven to be valuable tools for both OSHA and its Alliance participants. By entering into an Alliance with a party, OSHA is not endorsing any of that party's products or services; nor does the Agency enter into an Alliance with the purpose of promoting a particular party's products or services.

An implementation team made up of representatives of both organizations will meet to develop a plan of action, determine working procedures, and identify the roles and responsibilities of the participants in this Alliance. In addition, they will meet at least three times per year to track and share information on activities and results in achieving the goals of the Alliance. Team members will include representatives of OSHA's Directorate of Cooperative and State Programs, OSHA-approved Special Government Employees (SGEs) employed by ACC member companies, ACC member company representatives, ACC staff, and any other appropriate offices. OSHA will encourage State Plan States' participation on the team.

This Alliance does not change the regulatory or statutory requirements of OSHA's VPP, but rather, aims to provide a mechanism to recognize efficiencies between VPP and Responsible Care.

This agreement will become effective on the date that the last of the two signatories signs the Agreement, and will remain in effect for three years. Either signatory may terminate it for any reason at any time, provided they give 30 days written notice. This agreement may be modified at any time with the concurrence of both signatories.

Jonathan L. Snare
Acting Assistant Secretary
Occupational Health and
Safety Administration

Date

Jack N. Gerard
President & CEO
The American Chemistry Council

Date

Appendix A – Alliance Products
Attached for informational purposes only

Gap Analysis Tools

In general, OSHA and ACC agree that both VPP and Responsible Care® have strong commonalties in management leadership commitments, employee involvement, and training. Additionally, the values and philosophies of each program are similar regarding worksite analysis and hazard prevention control, but the depth of verification and specific requirements may differ. The Gap Analysis tools noted below serve as an aid to companies applying to both programs, and raise the confidence level of evaluators and auditors in identifying areas of consistency. The Gap Analysis Worksheets are of two varieties:

"Gap Analysis Worksheet for Facilities Currently RCMS® Certified, but Seeking VPP."
"Gap Analysis Worksheet for Facilities Currently Participating in VPP, but Seeking RCMS®."

For a facility that is already a VPP participant, note that any areas of consistency identified between VPP and Responsible Care refer only to the safety and health elements of Responsible Care—a Responsible Care auditor should still plan to address the same requirements as they pertain to environment, security, product stewardship, etc.

It should be noted, however, that judgment on whether any element or sub-element meets a particular program requirement must ultimately be made by a company's VPP evaluators for VPP requirements, and Responsible Care auditors for Responsible Care requirements.