Introduction
2009 saw another significant improvement in Yule Catto’s Safety Health and Environment (SHE) performance, even against the sharply improved performance of recent years. This improvement was sustained across all the Operating Divisions and across the geographical spread of Group companies. It was achieved despite the difficult trading conditions in 2009 and covered both safety and environmental impact.
The Group’s accident performance improved again compared to 2008’s record performance, with the Group recording
3 fewer over 3-day (O3D) lost time accidents (down from 13 to 10). The number of all Lost Time Accidents (LTAs) also reduced and our accident rate was over 30% below the latest average figure reported by Cefic (the European Chemical Industry’s representative body). The Group recorded very significant improvements in energy and water usage per tonne of production, down by 16% and 15% respectively, and there were further reductions in the tonnage of both hazardous and non-hazardous waste produced. The great majority of our other environmental indicators also showed further improvement, due to innovative solutions by Group companies and as the result of investment in environmental protection.
Our policy commitments
Responsible Care® was an initiative of the Canadian chemical industry in the 1980s and has now been adopted by the chemical industry around the world. Responsible Care® aims to improve and enhance the chemical industry’s SHE performance, year on year. Yule Catto has been committed to Responsible Care® since the 1990s and this commitment remains at the core of our efforts towards excellence in Corporate Social Responsibility. All Yule Catto sites are required to adhere to these principles and actively support the Group’s efforts to achieve continuous improvement in
our SHE performance.
In 2005 the Yule Catto Group was amongst the first group of UK Chemical Manufacturers to sign up to and support the UK Chemical Industries Association’s Sustainable Development (SD) guiding principles. The SD principles were adopted by the Yule Catto Board and are followed by the Group’s sites around the world. They have been used to set improvement targets, especially for our environmental performance, and to help the Group to define its route to a safe and sustainable business. The SD principles include a strong commitment to open reporting of our environmental performance and full respect for the people and communities amongst whom we work.
Highlights and achievements during 2009
Yule Catto uses five ‘headline’ SHE Key Performance Indicators (KPIs) to monitor its performance month by month. On all five, the Group’s performance improved markedly during 2009. Energy use per tonne of production fell by 16%; water use fell by 15%; total waste production fell by 18.5%; and the number of O3D accidents fell from 13 to 10, giving a frequency rate of 0.235 per 100,000 hours worked. These four KPIs are lagging indicators of performance. The Group also uses a leading indicator: the reporting of ‘near misses’ – defined as conditions which could potentially cause an injury, loss or environmental problem – by Group employees. Near miss reporting gives sites the chance to remove dangerous or potentially dangerous conditions before they can cause damage or personal injury. As a pro-active measure all sites were set a target of identifying, reporting and dealing with 2 near misses per employee during the year. Group employees showed that they recognise the importance of this initiative by reporting and dealing with 3.9 near misses per person, almost double the target.
The number of O3D accidents was down by over 20% but the frequency rate was only slightly better, due to the reduced number of hours worked. The rate was as good as the average for the UK Chemical Industry but did not quite meet our target for the year of 0.20. The Group performance on all LTAs also improved by over 6%: the frequency rate was 0.40 per 100,000 hours and remains some 30% below the average for the European chemical industry (as reported by Cefic).
The SHE headline KPIs are in addition to the Group’s continuing commitment to our 10-year SD targets, which cover
a wider range of environmental measures. As the Group has a history of significantly beating the SD targets, the headline KPIs are measured against tougher internal targets: an annual 4% reduction in both energy and water usage per production tonne; and a 5% reduction in waste disposed of off-site. The Group passed these more stringent environmental targets by a significant margin in 2009.
Nearly all of the Group’s other environmental targets were met, and indeed passed, in 2009 to give a performance better than target: for example the release of acid gases to atmosphere was reduced by a further 73%. However, Volatile Organic Compounds (VOC) releases increased significantly compared to previously reported figures and this is discussed further on page 17.
Given the recession and the accompanying reduction in production volume for many of our sites, the Group’s achievement is particularly notable. 2009 continued the Group’s record of improvement over the last 8 years; a record of continuous improvement which means that most of the easy changes have already been implemented. Sites now have to actively manage energy, water, waste and other materials to continue to make further performance improvements. It is notable that the Group’s use of water per tonne of product has been reduced by 50% since 2000 and energy use is down by 38%. The innovative approach to the disposal of waste is shown by Polymer Division’s increasing disposal of polymer waste by composting, producing a saleable soil enhancer rather than a waste problem.
Managing safety and environmental performance
Yule Catto believes that staff at all levels have to manage health and safety effectively if we are to achieve our aim of protecting the safety of all our personnel and have to operate our sites in a way that protects the environment at all times. This is achieved by managing our SHE performance in the same way that all other business objectives are managed.
The Group has an Accident and Incident Management System (AIMS) to assist in the management of all actual events and all near misses throughout the Group. The system received a significant upgrade during 2009 to improve the risk assessment of events and to include better information capture for process safety incidents, an area of increasing importance for the Group.
SHE performance is a primary duty for management at all levels in the Group and we have a number of management processes which assist this:
- SHE performance is discussed in all management meetings, as the first agenda item;
- Yule Catto conducts regular, in-depth SHE audits of all sites to assess performance and identify opportunities for improvement. The results of the audits are discussed both with the site involved and with wider management, for example at the Group Executive Committee;
- The Group AIMS is used to collect and analyse data on all accidents, incidents and near misses on our site. The system ensures that all of these are appropriately investigated, with the most serious or potentially serious incidents being fully investigated to root causes. The system is then used to ensure that the identified actions to prevent recurrence are put in place;
- Key measures of SHE performance are collected monthly or quarterly as appropriate and reported to the Group Executive and to the Board. This process is mirrored at company and site level to give management and staff a clear picture of current performance; and
- Senior managers have SHE targets as part of their annual objectives. Other employees have similar objectives set,
either on an individual or a site basis.
Health, safety and accident performance
The number of more serious accidents, those which cause an employee or contractor to lose more than 3 working days (O3D accidents), reduced again in 2009, falling to 10 compared to 13 in 2008. Notably no contractors suffered an O3D accident on any of our sites in 2009. As the number of worked hours also fell during the year, this improved performance only resulted in a small reduction in the frequency rate to 0.235 per 100,000 hours worked (100,000 hours is, very broadly, a working lifetime). These O3D accidents are those which are generally reportable to the regulatory authorities in the European Union and are a widely used comparison between different industries. The UK chemical industry is amongst the safest manufacturing industries in the world and the UK Chemical Industry Association (CIA) reports on its members’ performance. Our performance in 2009 puts Yule Catto at or just ahead of the average for CIA companies. Our current rate of O3D injuries is less than one quarter of what it was at the beginning of the decade.
Process safety and reportable safety incidents
The number of significant, reportable safety incidents remains at a very low level as indicated by the chart overleaf. None of the incidents during the year caused lasting harm to people or the environment.
There was one significant incident at our polymer plant in Germany where there was an uncontrolled polymerisation in a storage vessel. The incident involved a release of Butadiene from the vessel concerned and required off-site emergency services to attend. There was very little environmental or plant damage but 3 people were sent to hospital for observation. All were released quickly. Following the incident the European management team carried out an urgent safety review of the systems involved and identified a number of opportunities for improved operation in future. These were rapidly implemented and the plant returned to operation within 14 days with the full support of the German Regulatory Authorities.
Major safety improvement projects were implemented during the year in Vietnam and South Africa. These projects upgraded and significantly improved the reactor venting systems on both plants and will enable both sites to operate with an enhanced level of safety in the future.
Yule Catto participated in the production of a new Process Safety course by the UK Institution of Chemical Engineers (IChemE). IChemE ran the course several times during the year and Yule Catto sent a number of delegates to attend. Further staff training will be carried out in 2010.
Occupational health and hygiene
The Group has a comprehensive set of medical arrangements for our staff around the world. All staff who work with chemicals are provided with regular medical examinations. Whilst always respecting medical confidentiality, the doctors who provide the service in each country inform the local company if there are cases of reportable disease which could be caused by a work activity. They are also asked to inform the company if their overview of the health of our staff causes them concern. It is good to be able to report that there were no cases of a reportable disease recorded in 2009 or issues of concern highlighted by local doctors.
To support our work in occupational health, Yule Catto companies manage occupational hygiene, principally by
limiting exposure to the chemicals we process. This is done by the provision of appropriate equipment and work conditions which minimise exposure, and by the provision of Personal Protective Equipment (PPE) as a backup measure. In order to ensure that these measures are adequate the Group has introduced a risk assessment programme which is based on the standards of the UK Control of Substances Hazardous to Health regulations. This programme is being rolled out to all our companies around the world and is backed by the programme of Group SHE audits which give advice on adequate standards.
Audit programme
We have continued the Yule Catto Group SHE audits during 2009 and the results have been reported to the Group Executive on a regular basis. The audits are based on the principles of Responsible Care® management and give both individual companies and Yule Catto a view of each site’s current performance and set out areas for improvement.
The Executive monitors both the findings of the audits and the progression of improvement actions which arise from the audits.
Asset protection and insurance inspections
We can report that the Group’s losses from fire or process safety related incidents in 2009 continued at the very low level we have experienced in recent years. The Group’s SHE management systems and our internal SHE audit processes continue to contribute to this performance. The biennial insurance surveys carried out by our global property and business risk insurers serve as a ‘sense check’ on our own internal audits and also produce loss control recommendations of their own. These recommendations are assessed by Yule Catto for their practicality and cost-effectiveness, and progress is monitored both internally and by our insurers. This transparent partnership has helped the Group to reduce the cost of our global risk insurance by one third over the past five years.
Regulatory affairs: REACH and GHS
The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulations came into full force on
1 December 2008. The regulations required a significant amount of work by Group companies in 2008, including the pre-registration of some 1,250 chemicals with the European Chemicals Agency (ECHA). The first deadline for registration is 1 December 2010 and the workload in 2009 was focused on two areas: preparation for registration of the appropriate materials in 2010; and exchanging information with our customers and suppliers. Preparation for registration involves understanding which materials require registration and collecting the relevant information, not only from our suppliers and customers but also from any other companies who produce or market the same materials in the EU – with due regard to competition rules. Information collection naturally intersects with information sharing and these requirements mean that we must understand how our products are used and for what purposes, and then set up systems to collect and share appropriate safety information with those who need it.
The work in 2009 has shown that Polymer Division will need to register a number of monomers contained in polymers imported into the EU by Group companies. These registrations are to be made in 2010. William Blythe will also have a number of substances to register. The Pharma Division will only need to register some transported intermediates which require a much reduced data set.
These obligations are further complicated by the introduction of the new Globally Harmonised System (GHS) for Safety Data Sheets and hazardous product labelling. This new system has been negotiated by the United Nations and is being introduced in Europe at the end of 2010. Other jurisdictions around the world are currently planning the introduction of GHS, early in the next decade. REACH and GHS mean that the majority of our Safety Data Sheets and the accompanying labels for our products will need to be revised over the next few years.
The Group Executive Committee continues to monitor the implementation of REACH and is kept abreast of the forthcoming impact of GHS.
The Chemical Industry is committed to the concepts of SD. The UK CIA asked its member companies to formally commit to SD by signing a programme of SD goals in 2005. Yule Catto joined this programme at inception and has been committed to achieving them ever since. This commitment has been shown by a continuous record of improvement against the targets and a significant reduction of almost all our environmental impacts year on year.
2009 saw further significant improvements against all the SD measures we have reported in previous years with one exception. Improved measurements and better calculation methods have shown that the Group has significantly underestimated its releases of VOCs in recent years. There is no evidence of which Yule Catto is aware that these releases cause or have caused any immediate environmental harm, though we fully accept that they contribute to the overall environmental cost of our operations. Having become aware of this problem, which affects more than one site, the Group is actively seeking ways to reduce or abate these releases in the coming years.
For the fourth year in a row the Group achieved a very significant reduction in its specific energy consumption (that is energy consumption per tonne of production). Energy use fell by a further 16.9% in 2009 which means that the Group’s energy consumption is almost exactly one half of what it was in 2001. It has fallen by over 38% since the SD goals were signed in 2005 and is 34% below the target for 2010. The Group has set itself an internal target of achieving a further 4% reduction in energy consumption in 2010, which is roughly twice the rate of reduction which is expected by the Chemical Industry’s SD goals.
Although energy prices fell at the start of 2009, the long term trend is for energy prices to continue to rise; this makes the value of the energy saving achieved very significant for the Group. The change in the energy consumption per tonne in 2009 was equivalent to a saving of approximately £1.6 million.
Despite the very significant improvement in energy performance, Yule Catto’s impact on global warming was unchanged in 2009. The gains in energy efficiency were effectively negated by the recalculated VOC emissions.
None the less the Group is already performing over 20% better than its 2010 target. We expect this indicator to improve again when measures to reduce or abate VOC releases can be brought online.
Despite having already fallen by 97% since 2000, the Group achieved a further 73% reduction in its release of acidic gases to the atmosphere in 2009. This means that the releases are now less than 1% of what they were 9 years ago. By far the greatest sources of acid gases were the two Holliday Pigment plants, now no longer part of the Yule Catto Group. However, it is worth noting that the vast majority of the reduction arose from the very significant investment Yule Catto made in abatement equipment. The Group is currently producing only 1.6% of our target for 2010.
The security of the water supply and its quality is of great importance to every site in the Group, not least because water is an essential reactant in many of our processes and because the vast majority of our polymers are sold as dispersions in water. We are fortunate to have reliable sources of water for our sites and in a number of cases they come from our own renewable sources. Where we have this type of supply we monitor the source carefully so that we can be certain that it is not being depleted. Using water carefully and wisely is an important goal in ensuring that Group companies are fully sustainable.
Water usage fell sharply in 2009, by 15.2% compared to 2008, and has fallen markedly over the last decade so that it is just less than 50% of the consumption in the baseline year of 2000. It has fallen by over 28% since 2005 when the SD targets were set and is now only 62% of the 2010 target.
For Yule Catto the safe disposal of hazardous waste is an important responsibility which we fulfil by minimising the quantity of waste we produce and by working with reputable, regulated waste disposal companies. Our waste reduction programme has been very successful over the period since 2000 and current waste quantities are less than one sixth of what they were in 2000. Compared to the target for 2010 Yule Catto companies are producing only 16% of the target amount.
As noted in previous years we have adopted various strategies to reduce the quantity of waste produced, from ensuring that as much material as possible is reused or recycled, to sending non-hazardous organic waste to be disposed of via composting. These efforts have continued to bear fruit and the quantity of non-hazardous waste reduced by a further 7.5% in 2009. It is now only 36% of the quantity produced in 2005, the peak year.
Having risen sharply in 2008, the number of environmental incidents dropped back to previous levels in 2009. This significant improvement was due to further changes in the control of effluent discharge at William Blythe in Accrington, UK. Tighter limits had pushed them out of consent on a number of occasions in 2008 but improved control ensured that there was only one reportable incident during 2009.
The other reportable environmental incidents during 2009 were also nearly all to do with effluent discharge. Tighter limits and stricter controls are making this an active area of improvement for most of our sites and we expect to make significant investment in upgrades to our on-site treatment plants over the next few years.
Although limits were breached on 8 occasions in 2009 the tightness of the limits we operate to means that there have been no reports of environmental damage arising from these incidents. None the less each incident has been fully investigated and remedial actions needed to prevent recurrence have been implemented.