Chemical companies may think that by implementing ISO 14001 they meet the requirements for Responsible Care ®. ISO 14001 is an internationally accepted standard that provides the framework for an environmental management system. However, the Responsible Care ® program demands more. It adds a layer of requirements for Health & Safety and Security to be integrated along with environmental requirements.
Members of the American Chemistry Council (ACC) commit to implementing a system aligned to either the Responsible Care ® Management System (RCMS) Technical Specification or the RC 14001 which integrates the requirements of RCMS and ISO 14001 into one standard. Companies choosing the RC14001 standard can then claim conformity to both standards while putting in similar effort.
This article clarifies what each framework covers, where they overlap, and how to audit both efficiently
What RCMS Is and Who Requires It
Responsible Care ® is the American Chemistry Council’s (ACC) industry-wide performance initiative. It is not just an environmental standard. The need for a performance standard was identified following major incidents at chemical plants in the 1980s. RCMS is more than just a set of operational requirements. It outlines the requirements for a management system. Management systems include interaction from the highest level of the organization to the lowest level and enables effective interaction across processes.
ACC member companies are contractually required to certify to RC 14001 or RCMS; non-members may still be pulled in by customer or supply-chain requirements. Some organizations may voluntarily opt to confirm to the requirements of these standards. While RCMS is not a regulatory requirement, it is an obligation an ACC member opts to conform to.
RCMS follows the plan-do-check-act cycle and dovetails well with the requirements of ISO 14001. It expands upon the environmental requirements of ISO 14001 to include health & safety and security (HSS). It is also supported by the underlying ACC codes. Namely the Process Safety code, the Product Safety code and the Security code.
RCMS vs ISO 14001: Key Overlaps and Differences
Both standards, the RCMS and RC14001 are management system standards and thus based on the Plan-Do-Check-Act cycle. This means that both require the foundational aspects of a management system. These include leadership commitment, a documented policy, operational controls to manage identified risks, monitoring of the system, internal audits and management reviews.
Each of these standards also require the organization to determine their compliance obligations and to then take measures to meet them and evaluate them. The system as a whole is to be used to drive continual improvement. The key difference is that ISO 14001 has a focus solely on environmental requirements and does not address HSS requirements.
RCMS and RC14001 also integrate loosely via the Process Safety Code the OSHA PSM requirements. It is, however, not a replacement for these regulatory requirements. Further the two RC standards also address product stewardship which entails enhancing EHSS requirements throughout the supply chain from cradle to cradle.
Compared to ISO 14001, the RC standards also carry specific ACC-mandated elements (e.g., community outreach/CAER, security vulnerability assessments) with no ISO 14001 equivalent. There are also different certification requirements when it comes to RCMS and ISO 14001. The RCMS requiring just one audit by an approved provider every three years.
Why Chemical Companies Often Need Both
Depending on the customer base, especially when international, an organization can benefit from using the RC14001 standards. There is an increasing demand from stakeholders for sustainable production and procurement. As such many are seeking ISO 14001 certification. As a member of ACC companies that need to conform to RCMS may benefit from alignment with RC14001. Many downstream customers specify ISO 14001 certification contractually, independent of ACC membership
ACC membership requires member companies must certify to RC 14001 or RCMS on a fixed cycle to remain in good standing. There is however the added benefit to company reputation from an independent verification of practices to demonstrate to stakeholders and interested parties the organization’s commitment to EHSS goals.
Most chemical manufacturers end up needing both frameworks running concurrently rather than choosing one
Combining RCMS and ISO 14001 Audits
These standards aside, if your company has an integrated management system, there is no reason for you not to be doing integrated audits. So, what is an integrated audit? It is an audit where an auditor of team of auditors competent in the requirements of the various standards samples and assess the effectiveness of controls as determined and applied across the organizational processes. This to the various standards the company is certified to.
With ISO moving to the harmonized standard approach starting in 2013, most ISO management system standards including the RC14001 share the same 10 clause approach. This makes it easy to audit the system as there is shared audit evidence across standards. There is also cost savings to the company both from audit time of the auditor and the time of the auditee spent in the audit. There is less burden on the auditees overall from reduced audit fatigue.
An integrated audit essentially has a single audit schedule, combined checklists mapped to both standards’ (RCMS and ISO14001) clauses and one audit team covering both scopes. Companies choosing RC14001 have already integrated the requirements of RCMS and ISO 14001 into one standard and so perform a single audit. Integrated audits also result in fewer duplicate corrective actions for the same root cause
Building Auditor Competence for RCMS and RC14001
The above integrated audits require auditors preferably trained in both standards simultaneously, not two separately trained pools. This of course again to save on time and cost. QMII’s RC14001 Lead Auditor training approved by Exemplar Global covers the requirements of RCMS, RC14001 and the applicable ACC codes.
Auditors must understand the relevant additional RCMS elements in ISO 14001 and be able to be objectives if just performing and ISO 14001 audit versus an RCMS or RC14001 audit. An effective auditing course approaches audits as a positive activity that helps the organization identify improvement opportunities and audits as key in the preventive cycle. With this integrated competence auditors must remain objective and learn to look beyond documented processed to enable better inputs for leadership.
An auditing course apart from the requirements of the standard must also build competence in the principles of ISO 19011 and include hands on workshop that allow auditors to hit the ground running and to quickly contribute to their organization’s audit program.
Conclusion
In conclusion, RCMS and ISO 14001 aren’t competing standards, they’re complementary. RCMS adding in the HSS requirements to build on the foundation of an ISO 14001 if already in place. Those companies choosing between RCMS and RC14001 may want to opt from RC14001 given the later ease of integrating other ISO standards such as ISO 9001.
A well-trained auditor adds value to the system. They must provide good insight to the leadership on the state of the system, and this can only come from choosing a good sample, including whom to interview, questions to ask and documents to evidence.
ACC membership requires conformity to either RCMS or RC14001. Regardless of the option chosen by an organization, a trained audit team can only add value to the system. To learn more on the differences and build your auditing skills consider QMII’s RC14001 and RCMS Lead Auditor course.
