We transport and store numerous products and materials around the world, including commercial chemicals and pharmaceuticals, raw materials, intermediates, and waste, as well as technical materials and packaging, all of which could pose a hazard to health and the environment if handled incorrectly.
Our approach to safe transport and storage
It is our aim for all our shipments to reach our customers and sites safely, undamaged and with the required safety information. Several of the materials we store and transport are classified as hazardous. The storage of such hazardous goods and the transport thereof – whether by road, rail, plane, or ship – are governed by regulations applicable worldwide. To minimize risks to people and the environment, we apply strict safety regulations across the Group that of course also comply with applicable legislation. We conduct regular reviews to ensure that our own warehouses as well as those of third parties comply with these regulations. In addition, we train our employees accordingly.
How we achieve transport and warehouse safety
The overriding responsibility for transport and warehouse safety lies with our Group Environment, Health, Safety, Security, Quality (EQ) function (see Environmental stewardship), which defines the standards and guidelines applicable Group-wide. In addition, our individual sites are subject to various national and international regulations governing environmental stewardship and public safety, which local site directors are responsible for complying with.
Each of our sites around the world has an EHS manager and a dangerous goods manager, a position that equates to the Dangerous Goods Safety Advisor required by EU regulations. Both advise the site director on the safe storage and transport of hazardous goods while also monitoring compliance with statutory requirements and our own internal standards.
Our EHS managers are also responsible for monitoring our contract warehouses. Before signing a contract with a third-party warehouse operator, we assess whether they properly adhere to national and international storage and transport regulations and whether they are able to meet our additional requirements. We summarize the findings from this audit in an EHS report.
Integrating Versum Materials and Intermolecular
In the process of integrating Versum Materials and Intermolecular, which we acquired in 2019, we are reviewing their existing structures and processes for transport and warehouse safety, making adjustments as necessary.
Our commitment: Internal standards and international rules
Our Group-wide safety concepts and standards govern the safe storage of hazardous substances. Our Warehouse Safety standard, for instance, sets out measures to prevent materials from leaking or igniting and requires us to specify the dangers posed by any stored substance. Moreover, special safety rules apply to all warehouse employees.
Contract warehouses must also adhere to our high safety requirements. Before we sign a contract, providers must submit a statement detailing how they plan to meet our stringent safety standards. We also perform audits to ensure compliance from both our own warehouses as well as third-party facilities, utilizing a standardized checklist of the key requirements to help us assess potential contract warehouse risks. Furthermore, our Group standard Warehouse Requirements for Third-party Warehouses defines specific structural and organizational requirements for such facilities.
In Germany, the Technical Rules for Hazardous Substances (TRGS 510 “Storage of hazardous substances in non-stationary containers”) govern the storage of packaged hazardous materials and apply across all our warehouse and distribution centers worldwide. An updated version of the TRGS is due to take effect sometime in 2020, and we are currently working with the Committee on Hazardous Substances (AGS) to revise these rules. Moreover, all our existing sites comply with applicable requirements of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). As part of the integration process, we are examining whether the sites of the recently acquired companies Versum Materials and Intermolecular are GHS-compliant.
Our Group Transport Safety standard defines the safety levels for our facilities and is based on the United Nations Recommendations on the Transport of Dangerous Goods. This is especially important for sites in those countries with no local regulations covering the transport of hazardous materials.
All standards are reviewed as necessary, at a minimum every three years, and updated to reflect current requirements. When needed, we support our site directors in implementing relevant changes at the local level.
Enhancing transport and warehouse safety
In addition to the inspections conducted by our EHS and dangerous goods managers, we regularly perform Group risk-based audits to ensure that our sites comply with warehouse and transport safety regulations. We generally conduct these every four years, performing them more frequently at sites that pose a potentially higher risk. If major shortcomings are identified, we re-audit the respective site the following year. Conversely, we may decide to extend the period between audits at facilities where, based on the findings from previous audits, we deem the potential risk to be low. Our EHS managers are also responsible for monitoring contract warehouses.
In 2019, we audited nine of our warehouse facilities for compliance with our Warehouse Safety and Transport Safety standards. All audit observations were assessed to pinpoint the areas where we can improve. For instance, we subsequently revised our criteria for recycling shipping cartons in order to reuse as many original shipping boxes as many times as possible at our distribution centers. In 2019, we also audited four third-party warehouses and drew up the necessary corrective action plans. Beyond this, we started analyzing our current audit processes for contract warehouses at the end of the year.
We report transportation incidents and accidents in accordance with the Recommendations on the Transport of Dangerous Goods – Model Regulations (UN Orange Book, section 7.1.9) in conjunction with the criteria of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR, section 1.8.5). There was one reportable incident during 2019.
Employee training and best practice sharing
Our employees undergo regular training in line with their tasks and responsibilities, which is conducted by either their respective supervisor or our EHS and dangerous goods managers. Topics include internal standards and procedures, changes to international requirements, and proper incident management, and many of the subjects have ready-made training materials available that can be modified to reflect the circumstances of the respective site or country. All truck drivers employed by our company hold a dangerous goods driver’s license, provided that this qualification exists locally. In Germany, our truck drivers are subject to the requirements of the German Professional Driver Qualification Act (BKrFQG) and must therefore complete additional training on transporting hazardous goods and securing cargo.
Across the globe, we conduct around 1,000 internal and external seminars on transport and warehouse safety every year. The e-learning program we developed for hazardous material transport and storage is mandatory for logistics, EHS and dangerous goods managers. It currently features eight courses that are mandatory for the assigned participants.
Our dangerous goods managers hold regular conference calls to share their experiences and discuss current changes. All new EHS managers must complete EHStart-up! a three-day orientation seminar on environmental stewardship, safety and safe logistics. In 2019, 26 EHS managers took part in this training in Darmstadt.
Ensuring proper transport
We primarily use logistics companies to deliver our products to customers. In Germany, we transport the majority of our hazardous waste ourselves. Furthermore, we participate in the Transport Accident Reporting and Emergency Response System (TUIS) operated by the German Chemical Industry Association (VCI). Within this system, we exchange expertise and best practices on chemical transport with experts from other chemical companies and also provide hands-on assistance in the event of a chemical transportation accident. Our site fire departments in Darmstadt and Gernsheim collaborated with the fire departments in the region to develop the TUIS Messkonzept Südhessen. When a transportation or warehouse accident occurs, this standardized assessment system for southern Hesse allows us to quickly determine whether and how fast hazardous substances are spilling and spreading. In emergencies, our fire departments also provide on-site assistance using their specialized equipment.
Making transport vehicles safer
The safe transportation of dangerous goods requires safe vehicles, another factor our company takes very seriously. In Germany, for instance, we have been constantly evolving our SafeServer truck body technology. Under this design, the aluminum panels integrated into the side walls of the truck render the walls extremely stable. In 2019, 18 of our trucks had already been equipped with this technology.