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CDI

IMPCAS
Tank Container Audit Report
Management Questionnaire

3rd Edition
Nov-10
(RCMS)

TCO cover
Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute
International Marine Packed Cargo Audit Scheme

© 2010 Chemical Distribution Institute

All rights are reserved. Except for the normal review purposes no part of this document may be reproduced, utilised, stored
in any retrieval system or transmitted in form or by any means electronically or mechanically, include photocopying,
recording or by information, storage or retrieval system without the written permission of Chemical Distribution Institute
(CDI)

ACKNOWLEDGEMENT

The original material contained in this document was prepared by European Chemical Industry Council (CEFIC) which is
gratefully acknowledged.

The contribution made by all members of the IMPCAS Technical Committee in the preparation of this the Third Edition of
the Tank Container Operator Audit Report.

NOTICE OF TERMS AND USE

While this report has been developed using the best information currently available, it is intended to be used entirely at the
users own risk. No responsibility is accepted by the Chemical Distribution Institute (CDI) or any other person, firm,
corporation or organisation who or which has been in any way concerned with the furnishing of information or data, the
compilation or any translation, supply or sale of this report, for the accuracy of any information given herein or for any
omission here from or for any consequences whatsoever resulting directly or indirectly from information contained herein
even if caused by failure to exercise reasonable care.

TCO Introduction
Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 2 of 80
IMPCAS
Tank Container Questionnaire
List of Abbreviations

Index

Introduction

List Of Abbreviations

A. General Information

A.2 Company Safety History

B. Audit Summary

Sect 1. Tank Container Management


1.1 Management Responsibility
1.2 Personnel
1.3 QHSSE Performance Analysis
1.4 Management Review
1.5 Insurance
Sect 2 Safety, Health, Security and Environment
2.1 Risk Management
2.2 Safety
2.3 Occupational Health & Safety
2.4 Environment
2.5 Spill Prevention and Control

Sect 3 Security
3.1 Security Standards and Procedures
3.2 Site Security
3.3 Security Training

Sect 4 QMS and Responsible Care®


4.1 Quality System
4.2 Purchasing of Critical Materials and Services
4.3 Control of purchased materials and services
4.4 Suppliers of Critical Goods and Services
4.5 Contacts
4.6 Responsible Care®

Sect 5 Supply Chain Management and Subcontracting


5.1 Choice of Logistic Solutions
5.2 Supply Chain Management
5.3 Supply Chain Integrity
5.4 Subcontracting Services
5.5 Performance monitoring of logistics partners

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IMPCAS
Tank Container Questionnaire
List of Abbreviations

Sect 6 Equipment
6.1 Equipment Specification
6.2 Equipment Inspection, Maintenance, and Calibration
6.3 Equipment of Partners

Sect 7 Behaviour Based Safety


7.1 Service Partners Awareness

Sect 8 Intermodal Security


8.1 Security Plan
8.2 Security during intermodal transport moves
8.3 Legal requirements for High Consequence Dangerous Goods (HCDG) :
8.4 Best practices for intermodal transport security of HCDG :

Sect 9 Site Operating Procedures and Customer Interface


9.1 Operating Instructions
9.2 Customer Interface

Sect 10 Order Process and Operations


10.1 Order Planning
10.2 Order instructions for multimodal shipments
10.3 Tank Cleaning
10.4 Driver instructions (Driver Manual issued by Intermodal operator)

Sect 11 Administration
11.1 Records

Sect 12 Site Inspection


12.1 Office and buildings
12.2 Depot and Parking
Sect 13 Tank Containers
13.1 Tank containers and other associated equipment

TCO Introduction
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IMPCAS
Tank Container Questionnaire
List of Abbreviations

Preface

Chemical Companies use mainly third party Logistics Service Providers, often referred to as the "distribution industry", to
store, handle and transport their feedstocks, intermediates and finished products between their manufacturing plants and
end-use customers.

There is a need for Chemical Companies to be assured that these activities are carried out with due regard for safety and
quality, protection of employees, the public and the environment.

In the past the assurance was gained by individual chemical companies undertaking periodic audits of their logistic service
providers. This was a very fragmented approach that led to a multiplicity of auditing programmers, high costs and
inefficiency for the industry.

In the early 1990's, chemical companies recognised the need to take a fresh look at the safety, quality and environmental
aspects of supplier assurance. Initiatives begun then have evolved and developed into schemes such as that for marine
bulk operations, administered by CDI (Chemical Distribution Institute), the Safety and Quality Assessment Scheme (SQAS)
in Europe e.g. for Road Haulage activities, several protocols developed by ACC (American Chemistry Council). These
schemes offer a cost effective mechanism for monitoring the safety, quality and environmental performance of logistic
service providers. In addition, the documentation developed has led to a better understanding of the risks involved, and to
the establishment of more efficient safety management systems.

In 1990 both the European Chemical Industry Council (CEFIC) and the American Chemical Council (ACC) independently
discussed how to efficiently assess ship operators transporting chemical cargoes in ISO tanks, containers or trailers. The
protocols subsequently developed enable logistic service provides to have their quality, safety and environmental
management systems assessed in a uniform manner, and to avoid multiple assessments by different interested parties.
Assessment results can then be offered to any client and used in the selection of suitable service providers and for defining
any areas of improvement. Although this assessment system does not guarantee the safety, quality or value of the
company, the system will provide useful feedback directly to the service provider on the strengths and weaknesses
identified during the assessment results thereby creating/strengthening a parternership of mutual benefit, within which the
key safety and quality principles are practiced.

In 2000, the CEFIC “Ship” and “Shipping Company” questionnaires were revised in close co-operation with the
International Chamber of Shipping (ICS) and the International Association of Classification Societies (IACS), to take
account of existing safety and quality management systems used in the shipping industry: namely International Safety
Management (ISM) Code and ISO 9001:2000.

In 2001, these protocols were merged into global documents, combining the best of the CEFIC and ACC protocols. The
development of global documents for the assessment of other elements of the MPC supply chain is being anticipated in
the future. Meanwhile, current protocols for these other elements like freight forwarding, transfer terminals etcetera remain
valid on a regional basis.

TCO Introduction
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IMPCAS
Tank Container Questionnaire
Introduction

Background

The Questionnaire has been developed as part of the IMPCAS Tank Container Operator “Safety and Quality Assessment
System for Marine Pack Cargo Operations”

The aim of the Questionnaire is to give an accurate assessment of the MPC Operator at the time the audit is carried out.
The Questionnaire is essentially a safety, quality and environment protection assessment of a MPC Operator, its
operations and personnel.

The Questionnaire does not attempt to pass or fail the MPC Operator for any particular purpose but rather to give an
assessment of performance at the time of the audit.

The Auditor

The highest standards of ethical behaviour are expected from IMPCAS Auditors. The findings presented in the
Questionnaire are to be regarded as confidential and the property of the MPC Operator and on no account shall the Auditor
discuss the contents of the report with any third party.

The Auditor should be an observer only and should not interfere or become involved in working practices of the MPC
Operator or be a party in any discussion between the MPC operator, customer, local authorities, etc.

The Auditor shall not operate any equipment or advise any on any operational or constructional matters or give any advice
on how a particular non compliance or observation may be corrected.

A courteous and considerate approach is expected of the Auditor in all dealings with MPC Operator’s personnel. The
Auditor should take care to ensure that his actions do not in any way delay or interfere with normal operation of the MPC

Structure of the Questionnaire.

Questions are to be answered: ''Yes'', ''No'' or ''N/A''


Additional columns indictate whether it is Mandatory (M) or and Industry (I) requirement, and if it is applicable for
compliance with Responsible Care® (RC).
It should be noted that the M questions have increased significantly to (a) cater for changes in legislation and (b) additional
requirements of the IMPCAS Technical Committee who felt it necessary to raise the level of industry norm to a mandatory
requirement thereby improving QHSSE within the logistics supply chain.

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IMPCAS
Tank Container Questionnaire
Introduction

Specific Questions,

All Questions Core and Specific are to be answered “Yes” or “No”, with provision for a “N/A” answer when a facility or piece
of equipment does not exist.

Questions within the Questionnaire which clearly do not apply to the MPC Operator should be marked as N/A but Auditor to
make comment.

A “No” answer to a question does not necessarily imply that the MPC Operator is not in compliance. An explanation is
required, and comment must be made in the report.

Audit procedures

An audit shall not normally be carried out during the night. The only exception to this is when special arrangements have
been made with the MPC Operator prior to the Auditor arriving at the location.

The Auditor is expected to set a good example with respect to his own safety procedures during the period of the audit. The
Auditor should wear, as appropriate for the location, protective clothing and equipment including boiler suit, safety helmet,
safety shoes, safety gloves, ear protectors and goggles / safety glasses.

The MPC Operator’s safety procedures and notices displayed on site must be complied with by the Auditor. The Auditor
shall not enter restricted areas unless the Manager's permission has been obtained and any relevant permits / checklists
have been completed correctly. An Auditor shall not enter an enclosed space unless entry procedures are fully complied
with.

Opening meeting

On arriving at the location, the Auditor shall identify himself / herself to the Manager (or his representative) and outline the
objectives and requirements of the audit. The Auditor and the Manager (or his representative) should agree the sequence
for the audit. The audit should be planned and carried out in a manner which will not conflict with the safe operation of the
site. The Auditor should establish when key personnel will be available to assist with the audit.

During the audit, it is recommended that the Auditor is accompanied at all times by a responsible and suitably qualified
person(s), nominated by the Manager.

Proper planning at the Opening Meeting will enable the audit to be carried out efficiently and with the minimum of disruption
to the normal working of the site.

The Audit

It is a requirement that all questions (statements) in the Questionnaire are answered. Sampling of questions within the
report is not permitted. However, sampling within a particular question is permitted. For example, when assessing the
question on the operating instructions, the Auditor is not expected to sight every operating instruction on site but only a
sufficient number to make a broad judgment that they are displayed or readily available.

With a site in operation, some areas may not be capable of inspection, e.g. restricted loading bays. When any question is
not addressed due to operational reasons, the N/A check box should be marked and a note made in the relevant Remarks
section.

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IMPCAS
Tank Container Questionnaire
Introduction

Each question must have one of its check boxes marked.

Items in the report which are marked "Information only" and require data to be entered, must be completed.

If certain items of information are not available, a comment shall be made in the relevant Remarks section.

With the exception of "familiarity" type questions which by their nature are subjective, answers to all other questions must
be based on objective evidence. Objective evidence is defined as qualitative or quantitative information, records or
statements of fact which is based on observation, measurement or test and which can be verified.

The assurance of site staff should not be accepted by the Auditor as compliance with a particular question, without
objective evidence being produced to support their assertions.

An Auditor may request the demonstration or test of a particular piece of equipment. Should the request be refused, then
this should be noted in the relevant Remarks section, together with the reason for refusal.

Requests for a test of equipment should not be made where this will result in a major disruption to the sites normal
operations. i.e. stopping operations, blackout etc.

Closing meeting

On completion of the audit, the Auditor will hold a closing meeting with the Manager (or his representative). At the closing
meeting the Auditor shall provide the Manager with a copy of the record of negative answers and summary of observation
and remarks.

The Auditor shall discuss with the Manager (or his representative) the answers given in the Questionnaire and if requested
to do so, explain how the answers have been determined. Should a "No" answer or observation be contested, then the
Auditor shall give the Manager the opportunity to produce objective evidence to satisfy the requirement. If satisfactory
evidence of compliance is produced, then the answer to the question may be amended. Answers to questions, should not
be amended after the Auditor leaves the site.

The Manager should be requested to sign for the summary of observation and remarks. The Manager's signature is for
receipt only and does not infer that the Manager agrees with assessment or remarks.

The Manager (or his representative), must be given the opportunity to comment in writing on the contents of the
Questionnaire. Any written comments from the Manager (or his representative) will be entered to the database by the
Auditor.

The Audit does not result in a pass or fail. The Questionnaire is for consideration by potential customers only. The
Auditor shall not make any recommendations for the correction of any items marked as "No" in the Questionnaire, nor
indicate to the Manager, or any other person, the standard of the location or the possible eventual outcome of the audit.

TCO Introduction
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IMPCAS
Tank Container Questionnaire
Introduction

Processing the Report

During, or on completion of the audit, the Auditor shall enter all the Audit data (together with any comments from the
Manager), into his computer terminal and then up-load the report to the IMPCAS database in accordance with the
procedures governing control of the IMPCAS database system.

Except in exceptional circumstances (or when instructed by IMPCAS), copies of the Questionnaire should not be faxed, or
transmitted by any other means, to any person or business who is not the MPC Operator. Questionnaire data is privy to the
Auditor (which includes persons employed by the Auditor or under the direct control of the Auditor) and the MPC Operator.
Persons who do not have approved access to the Questionnaire data on the electronic database, are not permitted to sight
the Questionnaire data in hand-written or typed hard copy.

The use of the electronic database provides a level of security for the Questionnaire data which is easily compromised if
information is faxed or mailed to uncontrolled third parties.

The Auditor is responsible for the security of the Questionnaire data between the time of carrying out the audit and
uploading the data to the IMPCAS database. The Auditor shall ensure that a back up of the Questionnaire Data is
available in the event that the original Questionnaire Data is lost prior to uploading to the IMPCAS database.

Auditors are required to ensure that:


- All laptops and portable data storage devices are password protected.
- All MS Excel and pdf files are deleted from laptops and portable data storage devices after conveyance of the
document to the relevant party.
- Historic report data is only retained on office hard drives in the client.rep file format.

After uploading Questionnaire Data to the IMPCAS database all hard copy Questionnaire data shall be retained by the
Auditor for a period of the active life of the report.

The Auditor will be advised by IMPCAS if hard copy Questionnaire data is to be forwarded to IMPCAS for assessment or
other purposes.

Documentation

IMPCAS may print and store hard copies of the audit results in a central archive but will not provide copies of the reports to
interested parties unless authorised in writing by the respective of MPC Operator management.

It remains the MPC Operator’s prerogative to allow IMPCAS to provide copies of the completed IMPCAS documentation to
any interested (potential) clients. The operators themselves will not distribute the reports to customers.

The Auditor should return any advance documents received to the Operators Coordinator unless written consent is
achieved to do otherwise.

A certificate of attestation will be issued from the IMPCAS database.

TCO Introduction
Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 9 of 80
IMPCAS
Tank Container Questionnaire
List of Abbreviations

This List of Abbreviations provides a summary of the standard acronyms and abbreviations.

ACC American Chemistry Council


ACEP Accepted Continuous Examination Program
ADR European Agreement concerning the international carriage of dangerous goods by road

BBS Behaviour Based Safety

c Core Question
CDI Chemical Distribution Institute
CEFIC European Chemical Industry Council
CMR Convention Merchandise Routier
CTU Cargo Transport Units

D Desired
D&A Drug and Alcohol
DGA Dangerous Goods Advisor

EDI Electronic Data


EIR Equipment Interchange Receipt

GN Guidance Note

I Industry
ICS International Chamber of Shipping
IMDG International Maritime Dangerous Goods (Code)
IMPCAS International Marine Packed Cargo Audit Scheme
ISM International Safety Management Code (IMO)
ISO International Standards Organization

LSP Logistic Service Provider

M Mandatory
MPC Marine Pack Cargo

N/A Not applicable or not addressed

PES Periodic Examination Scheme


PPE Personal Protective Equipment

QHSSE Quality, Health, Safety Security & Environment,


QS Quality System

RC Responsible Care
RID Regulations Concerning the international carriage of dangerous goods by rail.

SDS Safety Data Sheets

SMS Safety Management System


SQAS Safety and Quality Assessment System

UN United Nations

TCO Introduction
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Section A GENERAL INFORMATION

A.1 General Information

Date of Audit :-_______________________________

Audited By :- __________________________________________________(Name)

Company information :-

Name Of Audited Company :-_______________________________________________

Address:-

Tel:-_____________________________ Fax:-____________________________

Contact Person(s) :-

Name :-

E-Mail :-

Name :-

E-Mail :-

Date of CDI Audit Report :- (if applicable)

CDI Audit Report Number :-

ISO Certificate issued by :- (if applicable)

ISO Certificate Valid Until:-

Branch Offices:-
Address:-

Address:-

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Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 11 of 80
Section A GENERAL INFORMATION

A.2 General Information

Company Safety History


Year to Date Previous Year

1 Number of loaded/empty uncleaned tank containers


shipped?

2 Percent loaded dangerous goods shipments?

3 Number of reported chemical incidents.

4 Number attributed to your company ?

5 Number attributed to your contractor?

6 Number attributed to shipping contractor?

7 Number attributed to Chemical Company?

8 Number caused by third party ?

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Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 12 of 80
Section A Guidance Notes

A.1 General Information

Date of Audit The date when the audit completed.

IMPCAS Audit For those international companies who have operating offices around the world, the
Report application of the IMPCAS Tank Container Management Questionnaire is as set out
hereunder.

The company must have a Core and Specific audit (every question) conducted by an
accredited auditor, if the audited company then chooses to have a further operating
centre audited within 6 months within the same region then the Core questions of the
audit are NOT REQUIRED to be completed, only the Specific questions need to be
answered.

If the same company has operating centres in different regions of the world then for
each region a complete IMPCAS assessment must be conducted.
The contents of this audit report are based on a visual assessment of the site as found
at the time of the audit.

The report is given in good faith, without prejudice and any responsibility is limited to the
exercise of reasonable care.

Examination & Shipping Lines actively participating in IMPCAS have access to Section 6.2 of the Audit
Test Report. This access allows shipping lines to verify the Operator's compliance with the
Compliance International Convention for Safe Containers, with respect to examination and testing.

The IMPCAS database will measure compliance with the ''Mandatory'' questions of 6.2
and indicate to the shipping line that the operator is in compliance. Should there be a
non-compliance at one of the operator's sites, then this will show the operator in non-
compliance. Non-compliance can be corrected and the database updated at any time
within the 3 year validation period. This may involve the auditor returning to the site to
close out the negative Mandatory questions.

TCO G-N General Information


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Section A Guidance Notes

A.2 General Information

This Page Is Left Intentionally Blank

TCO G-N General Information


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Section B Tank Container Audit Summary

Ref Closing Meeting, Observations and Remarks Yes No N/A

Record of Negative Answers form provided to the Manager

Summary of Observations and Remarks provided to the Manager

Observations and remarks discussed with the Manager

Summary of Observation and Remarks


Included are:-

1 Observations to negative answers requiring explanation.

2 Remarks to any answer or section deserving further explanation

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Section B Tank Container Audit Summary

B. Closing Meeting, Observations and Remarks

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Guidance Notes
Section B Tank Container Audit Summary
Closing Meeting, Observations and Remarks

Record of Negative Answers

The record of Negative Answers form shall be completed by the Auditor and given to the
Manager on completion of the audit

The Auditor shall request that the Manager signs for the form to confirm its receipt. Should
the Manager decline to sign for the receipt of the form then this shall be noted on the form
by the Auditor.

Summary of Observations and Remarks

The Summary of Observations and remarks should be completed by the Auditor and if time
permits a copy given to the Manager on completion of the Audit, or by other means as soon
as practically possible.

For those Negative Answers requiring an explanation, the explanation shall take the form of
an observation

The Auditor may make objective remarks to any answer or section deserving further
expansion.

Observations and Remarks should be numbered consecutively, but need not be sorted. It is
a function of the database to sort and present the Observations and Remarks.

Any comments the Manager wishes to make on the content of the questionnaire should be
noted on the list of Observations and Remarks. Any comments must be accompanied by
the Manager's signature.

TCO G-N Audit Summary


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Guidance Notes
Section B Tank Container Audit Summary
Closing Meeting, Observations and Remarks

This Page Is Left Intentionally Blank

TCO G-N Audit Summary


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Section 1 Tank Container Management
IMPCAS Core Questions
1.1 Management Responsibility Y N N/A cat

1.1.1 Company Policies


1.1.1.1 Does the company have a current written policy reflecting management's active commitment to :
1.1.1.1a c - Safety & Health ? M RC
1.1.1.1b c - Environment ? M RC
1.1.1.1c c - Quality ? M RC
1.1.1.1d c - Security ? M RC
1.1.1.1e c - Meeting customers requirements ? M RC
1.1.1.1f c - Training development ? I RC
1.1.1.1g c - Non conformance reporting ? I RC

1.1.1.2 Does the company policy include a programmes with regard to :


1.1.1.2a c - Behaviour Based Safety (BBS) ? or similar safety based programme ? I
1.1.1.2b c - Drugs and Alcohol ? M
1.1.1.2c c - Security (protecting people and property from loss by intentional destruction or theft) ? M
1.1.1.2d c - Employee involvement in all QHSSE matters ? I RC

1.1.2 Roles & Responsibilities


1.1.2.1 c Is there an organisation chart defining each individual's role within the organisation, including the I RC
responsibilities for QHSSE ?
1.1.2.2 c Are senior managers sufficiently visible and effective in carrying forward the SHEQ&S message? I RC

1.1.2.3 c Does the leadership interact and constructively encourage employees to be actively engaged in I RC
SHEQ&S performance improvement?
1.1.2.4 Is a person formally designated or a source defined to keep the company abreast of all relevant RC
legislation and legislative developments in the area of:
1.1.2.4a c - Safety & Health ? I RC
1.1.2.4b c - Environment ? I RC
1.1.2.4c c - Quality ? I RC
1.1.2.4d c - Security ? I RC

1.1.2.5 c Has the company formally appointed a DGA (Dangerous Goods Advisor) who meets and is suitability M RC
qualified to advise on legal requirements?
1.1.2.6 c Does the Dangerous Goods Advisor produce an annual report that includes investigation of incidents M RC
to Management ?

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Section 1 Tank Container Management
IMPCAS Core Questions
1.2 Personnel Y N N/A cat

1.2.1 Recruitment
1.2.1.1 Is there a written procedure which takes the following items into account :
1.2.1.1a c - previous employment and relevant experience ? I
1.2.1.1b c - relevant competence / education ? I
1.2.1.1c c - temporary staff/drivers ? I
1.2.1.1d c - are job descriptions issued on employment to new employees ? I
1.2.1.2 c Are all operating personnel (drivers, operators, etc) given a periodic medical examination dependent M
on the risks to which they are exposed ?
1.2.1.3 c Is there a written disciplinary procedure and are records retained ? I
1.2.2 Training
1.2.2.1 c Is there induction training for newly appointed managers, supervisors and operational personnel ? I RC

1.2.2.2 c Is there a process for reviewing the training requirements of managers, supervisors and operational I RC
personnel, on at least an annual basis ?
1.2.2.3 Are the following subjects covered in the training programme for operational personnel :
1.2.2.3a c - personal responsibility ? I RC
1.2.2.3b c - customer relationship ? I RC
1.2.2.3c c - media / crisis management training ? I RC
1.2.2.3d c - security awareness proportionate to the risk and their role within the business ? I RC
1.2.2.3e c - legal requirements ? I RC
1.2.2.3f c - specific work instructions ? I RC
1.2.2.3g c - incident reporting, investigation and analysis ? I RC
1.2.2.3h c - dangerous goods handling to meet updated legislation ? I RC
1.2.2.3i c - ratio filling of tanks ? M RC
1.2.2.3j c - specific supplier product or handling needs ? M RC
1.2.2.3k c - handling and use of Personal Safety Equipment ? I RC
1.2.2.3l c - company emergency procedures ? M RC
1.2.2.3m c - spill prevention and control ? I RC
1.2.2.3n c - Behaviour Based Safety (BBS) principles ? or similar safety based programme ? I RC
1.2.2.3o c - customs handling ? I RC

1.2.2.4 c Is a first aid training programme defined for identified persons and implemented ? M RC
1.2.2.5 c Are records maintained of who has been trained in what subjects ? I RC
1.2.2.6 c Is there a formal transfer of skills programme in place ? I RC
1.2.2.7 c Are refresher trainings carried out ? I RC
1.2.2.8 c Is the effectiveness of the training checked for each employee ? I RC

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Section 1 Tank Container Management
IMPCAS Core Questions
1.3 QHSSE Performance Analysis Y N N/A cat

1.3.1 Non-conformances Reporting, Investigation, Analysis and Corrective Action


1.3.1.1 Is there a documented system in place for identifying, recording and investigating non-conformances
regarding :
1.3.1.1a c - accidents ? I RC
1.3.1.1b c - incidents ? I RC
1.3.1.1c c - near-misses ? I RC
1.3.1.1d c - potential health issues ? I RC
1.3.1.1e c - reaches of security and threats? I RC
1.3.1.1f c - regulatory compliance? M RC
1.3.1.1g c - unsafe behaviour & unsafe conditions ? I RC
1.3.1.1h c - product contamination ? I RC
1.3.1.1i c - product discrepancies and short shipments ? I RC
1.3.1.1j c - quality of services ? I RC

1.3.1.2 c Is the DGA involved after an incident where dangerous goods were involved? RC
1.3.1.3 c Are immediate actions taken to avoid problems pending further investigation ? I RC
1.3.1.4 c Is there a procedure requiring the written notification within 24 hours of all non conformances to the I RC
customer involving their products ?
1.3.1.5 Is a detailed report prepared on non-compliances for the responsible management and the customer,
containing :
1.3.1.5a c - an investigation to establish the immediate cause of the non-conformance ? I RC
1.3.1.5b c - the identification of root causes ? I RC
1.3.1.5c c - recommendations for corrective actions to prevent recurrence ? I RC

1.3.2 QHSSE Trend Analysis and Improvement Objectives


1.3.2.1 Is there a process in place for the analysis of data to identify trends for :
1.3.2.1a c - Safety & Health ? I RC
1.3.2.1b c - Quality ? I RC
1.3.2.1c c - Security ? I RC

1.3.2.2 c Is there a process in place for the analysis of data to identify trends for Environment to measure and I RC
to improve the output of emissions?
1.3.2.3 c Has the Safety, Health, Environment and Security Plan of the company been reviewed against the I RC
applicable Responsible Care Programme ?
1.3.2.4 c Does the company promote the principles of Responsible Care to logistic partners? I RC

1.3.2.5 c Are specific SHEQ&S objectives set and monitored and is an action plan in place to achieve these I RC
objectives?
1.3.2.6 c Are specific QHSSE objectives set and monitored ? I RC

1.3.2.7 c Are annual targets set for improvement of the company's performance on QHSSE and is there an I RC
action plan how to achieve this improvement ?
1.3.2.8 c Is the effectiveness of the corrective and preventative actions based on the results of the trend I RC
analysis, monitored and documented ?

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Section 1 Tank Container Management
IMPCAS Core Questions
1.4 Management Review Y N N/A cat

1.4.1 Management Review


1.4.1.1 c Do formal annual management meetings review the following elements of the QHSSE management
systems:
1.4.1.1a c - Safety & Health ? I RC
1.4.1.1b c - Environment ? I RC
1.4.1.1c c - Quality ? I RC
1.4.1.1d c - Security ? I RC

1.4.1.2 c Does senior management monitor progress versus targets on SHEQ&S matters at every management I RC
meeting?
1.4.1.3 c Are safety walk abouts carried out and documented by appropriate managers on a periodical basis? I RC

1.4.2 Internal Communication


1.4.2.1 c Is there evidence that learning's on QHSSE issues are shared with the workforce ? I RC

1.4.3 Internal Audit


1.4.3.1 c Is there a documented plan for internal auditing of all areas referred to in IMPCAS TCO ? I RC
1.4.3.2 c Are internal audits carried out as per plan with competent auditors ? I RC
1.4.3.3 c For shortcomings identified in the audits, are action plans developed and are corrective actions taken I RC
?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
22 of 80
Section 1 Tank Container Management
IMPCAS Core Questions
1.5 Insurance Y N N/A cat

1.5.1 Insurance
1.5.1.1 c Does the company's insurance cover its contractual and legal liabilities related to the loss, damage of
carried/handled products for third party liability, and is the insurance in compliance with legal and
customer requirements, for following elements :
1.5.1.1a c - comprehensive public liability ? M
1.5.1.1b c - motor vehicle liability ? M
1.5.1.1c c - environmental liability ? M
1.5.1.1d c - goods in transit ? M
1.5.1.1e c - equipment (container / tank container liability ? M
1.5.1.1f c - back to back agreements with suppliers used for intermodal movements ? M

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
23 of 80
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.1 Risk Management Y N N/A cat

2.1 Risk Management


2.1.1 Is there a process to assess and document the Safety, Health, Environmental and Security risks ,
related to all activities of the company, considering following aspects:
2.1.1a c - start-up of new operations/activities (e.g. new products, new routes) ? I RC
2.1.1b c - change of operations/activities (Management of Change) ? I RC
2.1.1c c - periodic review of risks on current activities? I RC
2.1.1d c - does management of change and risk evaluation include environmental aspects? I RC
2.1.1e c - does management of change and risk evaluation include security aspects? I RC
2.1.1f c - has a risk assessment been conducted regarding computer information on customers, products I RC
and operations and are measures taken to mitigate identified risks?
2.1.2 c Is there a procedure present that legislative changes are communicated and implemented in the I RC
company ?
2.1.3 c Are measures taken to control/mitigate all identified potential risks ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
24 of 80
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.2 Safety Y N N/A cat

2.2.1 Personal Protective Equipment (PPE)


2.2.1.1 c Is there a written procedure defining what PPE has to be used under what circumstances ? M RC
2.2.1.2 c Is the PPE regularly checked (before use and at set intervals) and replaced when required ? M RC
2.2.1.3 c Is there specialised equipment with instructions/training for use for critical chemicals ? M RC
2.2.1.4 c Is there evidence that equipment is used ? I RC

2.2.2 On Site Emergency & Security Preparedness and Response


2.2.2.1 Is there a written plan for dealing with on-site emergencies and potential crises? I RC

2.2.2.2 Does this written plan contain the following information :


2.2.2.2a - individual responsibilities ? I RC

2.2.2.2b - training requirements for of the responsible personnel ? I RC


2.2.2.2c - arrangements for 24/7 hours coverage by trained responders ? I RC
2.2.2.2d - a list of the different parties to be informed with their contact details (customers, authorities) ? I RC

2.2.2.3 Is there a procedure for handling the information towards the neighbourhood, the press and other I RC
interested parties of serious accidents/incidents that happened on site?
2.2.2.4 Is the emergency equipment maintained, tested or checked on a regular basis? I RC
2.2.2.5 Has there been a comprehensive test of the emergency plan for on-site emergencies during the past I RC
12 months ?
2.2.2.6 Is there a documented business continuity plan and does this plan contain the customer contacts to be I RC
informed ?
2.2.3 Off-site Emergency Preparedness and Response
2.2.3.1 Does the company have appropriate twenty-four hour emergency plans consistent with governing I RC
regulations for all off-site activities.
2.2.3.2 Does this written plan contain the following information :
2.2.3.2a - training requirements for of the responsible personnel ? I RC
2.2.3.2b - a list of the different parties to be informed with their contact details (customers, authorities) ? I RC
2.2.3.2c - specific arrangements required by individual customers ? I RC
2.2.3.2d - transshipment facilities for all products ? I RC
2.2.3.2e - means to recover any damaged equipment ? I RC

2.2.3.2f - means to recover any contaminated land/product ? I RC

2.2.3.2g - a detailed off-site emergency plan ? I RC


2.2.3.2h - a 24 hr emergency telephone number and is it being made known ? I RC

2.2.3.3 In the event of an emergency can safety data sheets be easily transmitted to responders ? I RC
2.2.3.4 Does the emergency equipment include:
2.2.3.4a - oversized drums/UN approved salvage drums ? I RC
2.2.3.4b - eyewash station and /or bottles ? I RC
2.2.3.4c - absorbents/clean up materials ? I RC
2.2.3.4d - personal protective equipment for ALL products to be responded to ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
25 of 80
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.3 Occupational Health & Safety Y N N/A cat

2.3 Occupational Health & Safety


2.3.1 c Does the operating site have access to the DGA for advice for all products transported and/or handled M
2.3.2 c Are current Material Safety Data Sheets available from the manufacturers for all products transported M RC
and/or handled ?
2.3.3 c Has a review been carried out by a competent person on any new chemical to be transported before M RC
accepting the order (e.g. DGA) ?
2.3.4 c Are prevention measures being used to control all identified potential health hazards adequately ? I RC
2.3.5 c Are drivers/depot operators subject to a medical examination before employment ? I RC
2.3.6 c Are all drivers/depot operators given a periodic medical examination dependent on the risks to which I RC
they are exposed ?
2.3.7 c Are there systems in place to provide first aid capability ? I RC
2.3.8 c Is there a written reporting procedure for accidents and potential health hazards ? I RC
2.3.9 c Is a first aid training programme defined and followed ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
26 of 80
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.4 Environment Y N N/A cat

2.4 Environment
2.4.1 c Has the company identified the applicable environmental regulations relevant to the its operations ? M RC
2.4.2 c Has the company identified the applicable impacts and aspects of its operation ? I RC
2.4.3 c Is all material and waste, which are covered by regulations, stored and disposed of accordingly ? M RC
2.4.4 c Are waste disposal records retained as per legal requirements ? M RC
2.4.5 c Does the company have a waste reduction strategy ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
27 of 80
Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.5 Spill Prevention and Control Y N N/A cat

2.5 Spill Prevention and Control


2.5.1 Is spill prevention an integral part of:
2.5.1a c - equipment selection ? I RC
2.5.1b c - operators/drivers training programmes ? I RC
2.5.1c c - maintenance programmes ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
28 of 80
Section 3 Security
IMPCAS Core Questions
3 Security Y N N/A cat

3.1 Security standards and procedures

3.1.1 c Has the company appointed a person with appropriate qualifications and competence, as the person I
responsible for security ?
3.1.2 c Has the company developed a security plan which covers ADR/IMDG requirements and security M
arrangements as defined in ISO/PAS 28000, WCO Framework of Standards ?
3.1.3 Does the company Security Plan include :
3.1.3a c - a regular review of the operations and an assessment of potential vulnerabilities ? I
3.1.3b c - measures to reduce security risk ? I
3.1.3c c - reporting of and dealing with security threats, breaches of security, and security incidents ? I
3.1.3d c - testing/evaluation of the company security provisions are reviewed on a yearly basis ? I
3.2 Site security
3.2.1 c Is the site properly secured with fences and gates, well lit and not accessible to the general public ? I
3.2.2 c Is there a system to monitor entry and movement of all personnel and visitors on site through positive I
identification ?
3.2.3 c Is there a procedure in place, requiring a.o. documented periodical inspections, to identify breaches in I
the security of the buildings ?
3.2.4 c Is there a system to monitor entry and movement of vehicles on site ? I
3.2.5 c Is there a system to protect computer information on customers, products and operations ? I
3.2.6 c Is the site manned 24/7 or adequate security achieved by other means ? I
3.3 Security Training
3.3.1 Do all involved personnel attend security awareness training which covers :
3.3.1a c - recognition of security risks ? I
3.3.1b c - methods to address and reduce security risk ? I
3.3.1c c - actions to be taken in the event of a breach of security ? I
3.3.1d c - recognition of internal conspiracies ? I
3.3.1e c - maintaining cargo integrity ? I
3.3.1f c - determining and addressing unauthorised access ? I

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
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Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care® Y N N/A cat

4.1 Quality System


4.1.1 c Does the quality manual clearly describe a system of quality management as per ISO 9001:2008 or I RC
equivalent?
4.1.2 c Does the scope of the quality system cover the following elements :
4.1.2a c - company policy on quality assurance? I RC
4.1.2b c - the organisation structure and lines of communication ? I RC
4.1.2c c - clearly defined responsibility, authority and interfaces ? I RC
4.1.2d c - non-conformances Reporting, Investigation, Analysis and Corrective Action ? I RC
4.1.2e c - customer contract review ? I RC
4.1.2f c - the method whereby the processing of customer orders is controlled ? I RC
4.1.2g c - the method whereby handling of non-conforming product/service and corrective action are I RC

4.1.2h c - the method whereby purchasing activities are controlled ? I RC


4.1.2i c - the method whereby the maintenance of equipment is controlled ? I RC
4.1.2j c - establishing training program ? I RC
4.1.2k c - issue, revision and distribution of controlled documents ? I RC

4.2 Purchasing of Critical Materials and Services


4.2.1 c Are the specifications for critical services and products communicated to suppliers in writing ? I RC

4.3 Control of purchased materials and services


4.3.1 c Are suppliers of critical goods and services reviewed and selected on the basis of a quality I RC
4.3.2 c Are goods inspected and services evaluated for conformance to agreed specification ? I
4.4 Suppliers of critical goods and services
4.4.1 c Are non conformances resulting from suppliers of critical goods and services dealt with as per Section I RC
1.3 Non-conformances Reporting, Investigation, Analysis and Corrective Action ?
4.5 Contacts
4.5.1 c Is there a contingency plan to maintain the planning capability in the event of sickness, holidays, I
unforeseen circumstances, etc ?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
30 of 80
Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care® Y N N/A cat

4.6 Responsible Care®


4.6.1 c Has the company a policy statement which clearly reflects a commitment to the Responsible Care I RC
Guiding Principles?
4.6.2 c Do the company policy statements drive setting Responsible Care/EHSS objectives and targets? I RC
4.6.3 c Do the company policy statements commit to comply with legal and Responsible Care related I RC
requirements?
4.6.4 c Does the management system allow for verification that resources are sufficient and appropriately I RC
allocated to meet Responsible Care goals, objectives and targets?
4.6.5 c Does the organization assist in the development of responsible laws, regulations and standards that I RC
safeguard the community, workplace and environment?
4.6.6 c Is there a system to assure that the organization is meeting it's Responsible Care reporting obligations I RC
according to established timetables?
4.6.7 c Does the policy statement encourage employees' involvement in and commitment to the company's I RC
Safety, Health, Environment and Quality objectives?
4.6.8 c Is there a well publicised award/reward scheme to encourage improvements in Safety, Health, I RC
Environment and Quality Performance?
4.6.9 c Are the company policy statements communicated to stakeholders and members of the public? I RC
4.6.10 c Does the company have Bulletin Boards (or other means of open communication i.e. websites) which I RC
promote Safety, Health, Environment and Quality matters ?
4.6.10a c - Are bulletins issued at regular intervals ? I RC
4.6.11 c Is there a system to assess stakeholder perspectives? I RC
4.6.12 c Do the established Responsible Care/EHSS objectives and targets take into consideration stakeholder I RC
perspectives?
4.6.13 c Is the effectiveness of internal and external communication plans measured? I RC
4.6.14 c Does the company Emergency Plan clearly reference the different types of incident that the company I RC
may suffer?
4.6.15 Do the Emergency Plan references to different types of incidents include:
4.6.15a c - Product incidents? I RC
4.6.15b c - Waste incidents? I RC
4.6.15c c - Transport incidents? I RC

4.6.16 c Does the company actively participate in the development, implementation and maintenance of I RC
community emergency preparedness plans?
4.6.17 c Does the company Emergency Plan make consideration for community recovery needs? I RC
4.6.17a c - Is there evidence to show that community recovery needs are periodically reviewed, particularly for I RC
new products being stored?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
31 of 80
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.1 Choice of Logistic Solutions Y N N/A cat

5.1 Choice of Logistics Solutions


5.1.1 c Is there a documented process for defining and choosing the logistics solution and selecting the I RC
service partners for each business assigned to the company including a risk assessment covering
SHEQ&S elements?
5.1.2 Does the logistics solution cover the following aspects ?
5.1.2a c - Safety & Health ? I RC
5.1.2b c - Environment ? I RC
5.1.2c c - Quality ? I RC
5.1.2d c - Security ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
32 of 80
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.2 Supply Chain Management Y N N/A cat

5.2 Supply Chain Management


5.2.1 Do annual QHSSE targets communicated to all involved service providers in the supply chain include:
5.2.1a c - Safety & Health ? I RC
5.2.1b c - Environment ? I RC
5.2.1c c - Quality ? I RC
5.2.1d c - Security ? I RC

5.2.2 Does the company follow-up the service providers' actions to ensure achievement of the targets ? I RC

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
33 of 80
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.3 Supply Chain Integrity Y N N/A cat

5.3 Supply Chain Integrity


5.3.1 Has the company a documented process to control its services from loading point to delivery at the I
final consignee ?
5.3.2 Are all customer instructions and requirements followed through over the complete supply chain, when I
multiple service partners are involved ?
5.3.3 Does the company have a formal process in place enabling on-time delivery reporting and follow-up at I
all stages of the supply chain (including identity of person and reason causing or requesting changes)
?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
34 of 80
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.4 Subcontracting Services Y N N/A cat

5.4.1 Subcontracting policy


5.4.1.1 Does the company have a written policy for subcontracting transport and transport related services I RC
(including selection process, performance assessment and monitoring) ?
5.4.1.2 Are the requirements and restrictions of the customer chemical companies reflected in the I RC
subcontracting policy ?
5.4.1.3 Does the company policy reflect the restrictions regarding spot subcontracting for chemical haulage ? I
5.4.2 Approved subcontractors
5.4.2.1 Does the company maintain an up-to-date list of fully approved subcontractors ? I RC
5.4.2.2 Are the subcontracting requirements (as outlined in the performance criteria of 5.3.1.) defined in a I RC
written agreement, monitored and documented for all approved subcontractors ?
5.4.2.3 Are the drivers/operators of approved subcontractors taking part in the company's safety and quality I RC
trainings and programs ?
5.4.2.4 Does the company hand out Driver Handbooks to drivers of approved subcontractors or check that the I
subcontractor's handbook is consistent with its own ?
5.4.3 Unplanned spot services by subcontractors
5.4.3.1 When the company has to deploy unplanned resources in the supply chain, are the minimal service I
requirements defined and requested for these service partners ?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
35 of 80
Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.5 Performance monitoring of logistics partners Y N N/A cat

5.5.1 Performance Criteria


5.5.1.1 Does the written service agreement with each subcontractor contain the requirements and standards
related to following criteria :
5.5.1.1a - compliance with all relevant national and international regulations and laws ? M RC
5.5.1.1b - operating licenses consistent with the activities and operations ? M RC
5.5.1.1c - drivers/operators holding valid ADR licenses/certificates ? M RC
5.5.1.1d - working/driving hours compliance and keeping records ? M RC
5.5.1.1e - drugs and alcohol policy ? I RC
5.5.1.1f - vehicle parking ? I RC
5.5.1.1g - carry forward transport and customs documents to all service partners in the chain, including EIR I RC
(Equipment Interchange Receipt) if required ?
5.5.1.1h - use of emergency number / emergency response capabilities ? I RC
5.5.1.1i - appointment and fulfillment of the duties of the DGA ? M RC
5.5.1.1j - vehicle / equipment maintenance, inspection and testing? M RC
5.5.1.1k - use of approved tanker cleaning stations ? I RC
5.5.1.1l - observation of instructions/practices at loading and unloading sites (including working on height, I RC
safe tank entry procedure, sampling responsibilities and safe sampling practices, cleanliness of
equipment) ?
5.5.1.1m - adequate driver selection and training, driver manual content, driver pre-start and post-loading I RC
checks, defensive driver training, BBS, wearing seat-belts, parking of vehicles, weight limits in
different countries) ?
5.5.1.1n - secondary subcontracting of haulage ? I RC
5.5.1.1o - comprehensive insurance coverage ? M RC
5.5.1.1p - handling of and reporting non-conformances ? I RC
5.5.1.1q - accident/incident reporting (incl. near-miss reporting) ? I RC
5.5.1.1r - confidentiality of operational and commercial data ? I RC
5.5.1.1s - security provisions as required by applicable legislation ? M RC

5.5.1.2 Is there a procedure and register in place for periodic testing of flexible hoses, which includes the
following elements :
5.5.1.2a - compatibility of the hose and cargo ? I RC
5.5.1.2b - identification of different types and numbering ? I RC
5.5.1.2c - periodic inspection and recording of results ? I RC
5.5.1.2d - periodic pressure testing ? I RC
5.5.1.2e - electrical continuity ? I RC

5.5.2 Performance monitoring process


5.5.2.1 Has the company a documented process for the evaluation and performance monitoring of all its I RC
service partners ?
5.5.2.2 Does the company use CDI/SQAS packages to evaluate sub contractors ? I
5.5.2.3 Is a joint improvement plan implemented and monitored ? I
5.5.2.4 Does the company have authority to perform on-site QHSSE assessments and is this contained in the I
agreement ?
5.5.2.5 Do you retain evidence of compliance with the performance criteria :
5.5.2.5a - was verified before the agreement was signed with each subcontractor, and repeated regularly ? I
5.5.2.5b - is followed-up on a regular basis through dialogue and improvement action programmes with the I
subcontractors ?
5.5.2.6 Are scheduled meetings held with selected subcontractors at management level to review objectives I RC
and performance ?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
36 of 80
Section 6 Equipment
IMPCAS Specific Questions
6.1 Equipment Specification Y N N/A cat

6.1 Equipment Specification


6.1.1 Is there a procedure covering all aspects and responsibilities for the purchase/lease of equipment ? I
6.1.2 Is there a written specification for the purchase or lease of each tank/tank container and associated I
equipment ?
6.1.3 Does the written specification include the following items :
6.1.3a - ground operated vent valves ? I
6.1.3b - retro-reflective markings ? I
6.1.3c - customer requirements ? I

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
37 of 80
Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance, and Calibration Y N N/A cat

6.2.1 Equipment Inspection and Maintenance (Service)


6.2.1.1 Is there a documented programme for preventive inspection and maintenance, covering the following
equipment :
6.2.1.1a - tank containers ? I RC
6.2.1.1b - earthing points ? I RC
6.2.1.1c - integrated auxiliary equipment ? I RC
6.2.1.1d - framework ? I RC

6.2.1.2 Is there a documented procedure:


6.2.1.2a - to monitor the inspection and maintenance process ? I
6.2.1.2b - to remove from service equipment with faults affecting safety and integrity ? I
6.2.1.2c - to remove from service equipment that is overdue for inspection, examination or test ? I
6.2.1.2d - to rectify defects and record all maintenance and repairs, including details of items replaced and I
any follow-up actions ?
6.2.1.3 Are service records maintained up to date ? I
6.2.1.3a - Are service records retained on a central file and accessible by all sites ? I
6.2.1.4 Do service records indicate that all tank containers and their fittings are serviced on a regular basis ? M RC

6.2.1.5 Do service items include :


6.2.1.5a - valves and relief valves ? M
6.2.1.5b - couplings ? I
6.2.1.5c - gaskets/seals ? I
6.2.1.5d - gauges ? M
6.2.1.5e - safety equipment including emergency control cable, handrails, ladders and flooring ? I
6.2.1.5f - temperature control units ? I
6.2.1.6 Are the following types of temperature control units serviced:
6.2.1.6a - hot oil ? I
6.2.1.6b - steam ? I
6.2.1.6c - warm water ? I
6.2.1.6d - electrical ? I
6.2.1.6e - refrigerator ? I
6.2.1.6f - generator (diesel) ? I

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
38 of 80
Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance, and Calibration Y N N/A cat

6.2.2 Statutory Examination and Testing


6.2.2.1 Is there a documented procedure for the examination and testing of tanks, in accordance with the M
International Convention for Safe Containers?
6.2.2.2 Do records of test certificates indicate that tank containers are subjected to the required periodic M
examination and testing ?
6.2.2.3 Does the company:
6.2.2.3a - engage an approved program a Periodic Examination Scheme (PES) ? M
6.2.2.3b - engage an approved program an Accepted Continuous Examination Program (ACEP) ? M
6.2.2.3c - post individual tank test certificates on the IMPCAS database ? M

6.2.2.4 Are tank test certificates available electronically ? M


6.2.2.4a - Is this a corporate facility, centrally located and accessible by all sites ? I
6.2.2.4b - Does the facility allow for examination and test data on all leased tank containers to be listed ? I
6.2.2.5 Do records of examination clearly indicate the following inspections have been completed as required
by International Convention for Safe Containers:
6.2.2.5a - Internal inspection ? M
6.2.2.5b - External inspection of non-insulated and insulated tanks (as far as can be reasonably observed) ? M
6.2.2.5c - Thickness measurements ? M
6.2.2.5d - Checking of valves and settings ? M
6.2.2.5e - Checking of equipment ? M
6.2.2.5f - Checking of tightness ? M
6.2.2.5g - Hydraulic test pressure ? M
6.2.2.5h - Pressure test of heater ? M
6.2.2.5i - Examination of frame ? M
6.2.2.5j - Examination of markings ? M
6.2.2.5k - Sighting and fixing of the Safety Approval Plate ? M
6.2.2.6 Is there a documented procedure in place to ensure that the CSC remains valid for the duration of the M
sea voyage to the final discharge port ?
6.2.2.7 Is there a documented procedure in place to allow a loaded or non-cleaned tank to be shipped ? M

6.2.3 Identification and Calibration of Measuring & Test Equipment


6.2.3.1 Are calibration procedures in place, incl. identification of all measuring equipment ? I
6.2.3.2 Is calibration carried out in accordance with legislation for the following critical equipment :
6.2.3.2a - oxygen meters ? M
6.2.3.2b - flammable gas detectors ? M
6.2.3.2c - instruments for measuring concentrations of toxic gases and vapours ? M
6.2.3.2d - temperature gauges ? I
6.2.3.2e - tank pressure gauges ? M
6.2.3.3 Are calibration records maintained ? M

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
39 of 80
Section 6 Equipment
IMPCAS Specific Questions
6.3 Equipment of Partners Y N N/A cat

6.3 Equipment of Partners


6.3.1 Does the company have evidence that the purchase or lease of each vehicle and associated M
equipment used by selected subcontractors is in line with the statutory requirements and industry
standards ?
6.3.2 Does the company have evidence that selected subcontractors have a documented programme in I
place for preventive inspection and maintenance of their equipment ?
6.3.3 Does the company have evidence that selected subcontractors have a program in place that their I
vehicles and their fittings are serviced on a regular basis ?
6.3.4 Does the company have evidence that selected subcontractors are carrying out timely statutory M
inspections of tractor units and trailers ?
6.3.5 Does the company have evidence that selected subcontractors are carrying out calibration in M
accordance with legislation, for designated critical equipment, when applicable ?

TCO Audit Questionnaire


Rev: IMPCAS 11/2010
(C)2010 Chemical Distribution Institute
40 of 80
Section 7 Behaviour Based Safety (or equivalent programme)
IMPCAS Specific Questions
7.1 Service Partners Awareness Y N n/a cat

7.1 Service Partners Awareness


7.1.1 Does the company promote the implementation of the principles of Behaviour Based Safety (BBS) or I
equivalent programme) on driving and loading/unloading with all its service partners ?
7.1.2 Are goals and targets set and communicated in relation to BBS? I
7.1.3 Has a BBS project implementation plan been set up with targets, resourcing and timeline ? I
7.1.4 Have the respective responsibilities of all personnel in the implementation of BBS been identified ? I
7.1.5 Has a BBS project implementation plan been set up and communicated with goals & targets,
resourcing and timeline ?
7.1.6 Does the company monitor the implementation of those principles with its service partners ? I
7.1.7 Are key performance indicators identified and measured, such as :
7.1.7a - accidents and incidents whilst in transit ?
7.1.7b - accidents and incidents at loading point ? I
7.1.7c - accidents and incidents at unloading point ?
7.1.7d - fuel consumption per ton per km ?
7.1.7e - damages ? I
7.1.8 Are the results and learning's from BBS reflected in the refresher programmes ? I

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Section 8 Intermodal Security
IMPCAS Specific Questions
8 Intermodal Security Y N N/A cat

8.1 Security Plan


8.1.1 Has the company developed security provisions regarding its transport distribution information ? M
8.1.2 Does the company implement measures to ensure the security of the products and transport
information throughout the chain of its service partners, including at :
8.1.2a - hauliers ? M
8.1.2b - depots ? M
8.1.2c - cleaning stations ? M
8.1.2d - at the interface with intermodal transport ? M
8.1.3 Is the handover/transfer of security with the associated responsibilities signed and documented ? M
8.2 Security during intermodal transport moves
8.2.1 Does each company employee and subcontractor employee carry with them means of identification, M
which includes their photograph ?
8.3 Legal requirements for High Consequence Dangerous Goods (HCDG) :
8.3.1 Does the security plan include all associated areas as defined in section 1.10.3 of ADR High M
Consequence Dangerous Goods (HCDG) and Section 1.4 of IMDG ?
8.4 Best practices for intermodal transport security of HCDG :
8.4.1 Does the company have measures to monitor the movement of HCDG whilst in transit ? M
8.4.2 Are all fully loaded tank/tank containers containing HCDGs sealed and seal numbers provided I
separately (electronic or on paper) ?
8.4.3 Are seal discrepancies for HCDG investigated thoroughly, the shipment rejected if necessary, security I
personnel notified and extreme care taken if there is evidence of seal tampering ?

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.1 Operating Instructions Y N N/A cat

9.1 Operating Instructions


9.1.1 Does the site have all the required operating licenses (If required) in line with the activities carried out M RC
at the site ?
9.1.2 Is there a documented system in place for recording and investigating non-conformances regarding :
9.1.2a - product contamination ? I RC
9.1.2b - product discrepancies ? I RC
9.1.2c - transport documentation ? I RC
9.1.2d - transport legislation infringements ? I RC
9.1.2e - placarding/labeling/marking ? I RC
9.1.2f - use of EIR (Equipment Interchange Receipt) / damage occurrence ? I RC
9.1.2g - delay in departure of shipping/rail ? I RC
9.1.2h - short shipments ? I RC
9.1.2i - delays to schedule, transfer time and on-time delivery performance ? I RC

9.1.3 Are there comprehensive procedures at the facility including work permit requirements, to ensure
safety and to avoid exposure to hazardous materials, for following operations :
9.1.3a - entry into confined spaces ? M RC
9.1.3b - breaking of containment (pumps/compressors/lines) ? I RC
9.1.3c - hot work ? M RC
9.1.3d - work on electrical circuits/equipment (lock out system) ? M RC

9.1.4 Are there also comprehensive procedures / instructions at the facility for following operations :
9.1.4a - clean up and disposal of chemical spillages ? M RC
9.1.4b - parking segregation for vehicles/tanks/tank containers carrying different classes of hazardous M
product ?
9.1.4c - safe loading/unloading practices ? I RC

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.2 Customer Interface Y N N/A cat

9.2 Customer Interface


9.2.1 Has the responsibility for the loading of the product been defined between the chemical company and
the tank container operator regarding :
9.2.1a - site access requirements at the loading site ? I RC
9.2.1b - party at the loading site to report to for loading ? I RC
9.2.1c - split of responsibilities agreed between driver and operators at loading site ? I RC
9.2.1d - check on all closures to prevent spillage ? I RC
9.2.1e - making the connection between tank/tank container and the loading point ? I RC
9.2.1f - weight to be loaded ? I RC
9.2.1g - placarding, labeling and marking of the tractor / tank container ? M RC
9.2.1h - authorisation to start loading ? I RC
9.2.1i - fitment of NITROGEN label on man lid if under nitrogen blanket ? I RC
9.2.1j - co-operation by the driver in the loading process ? I RC
9.2.1k - check of the leakproofness of the closing devices after loading ? I RC
9.2.1l - documents accompanying the loading process (before/during/after) ? I RC
9.2.1m - the presentation of the Tank Cleaning Document prior to loading ? I RC
9.2.1n - required hose length/couplings ? I RC
9.2.1o - delivery points, vehicle restrictions and unloading facilities ? I RC

9.2.2 Has the responsibility for the unloading of the product been defined between the chemical company
and the tank container operator regarding :
9.2.2a - site access requirements at the unloading site ? I RC
9.2.2b - party at unloading site to report to for unloading ? I RC
9.2.2c - split of responsibilities agreed between driver and operators at unloading site (BBS I RC
loading/unloading) ?
9.2.2d - making the connection between tank/tank container and the unloading point ? I RC
9.2.2e - authorisation to start unloading ? I RC
9.2.2f - co-operation by the driver in the unloading process ? I RC
9.2.2g - check of the leakproofness of the closing devices after unloading ? I RC
9.2.2h - documents accompanying the unloading process (before/during/after) ? I RC

9.2.3 Is there a procedure in place to ensure that when drivers are requested by consignors or consignees I RC
to draw a sample from the top of the vessel that feedback is initiated to the consignor and that this
communication has been followed up ?
9.2.4 Is there a procedure in place to ensure that when drivers are requested by consignors or consignees I RC
work on top of the vessel and no (proper) fall protection is available that feedback is initiated to the
consignor and that this communication has been followed up ?
9.2.5 Are meetings held with selected customers to :
9.2.5a - review the QHSSE performance ? I RC
9.2.5b - agree on QHSSE targets and improvement programmes ? I RC

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations Y N N/A cat

10.1 Order Planning


10.1.1 Is there a written procedure for order processing and equipment scheduling ? I
10.1.2 Does the planning section communicate all relevant information and instructions to the
driver/subcontractor, including but not limited to :
10.1.2a - full proper shipping name and UN Number of the product ? I RC
10.1.2b - hazardous nature of the material ? I RC
10.1.2c - consignor/consignee details ? I RC
10.1.2d - time and collection/delivery of product ? I RC
10.1.2e - tank/tank container capacity / suitability ? I RC
10.1.2f - weight/litres to be loaded ? I RC
10.1.2g - maintenance of product temperature ? I RC
10.1.2h - product compatibility (multi loads) ? I RC
10.1.2i - product compatibility (previous loads) ? I RC

10.1.3 Are there procedures in place to ensure that maximum allowable weights are not exceeded ? M
10.2 Order instructions for multimodal shipments
10.2.1 For multimodal shipments, does the order handling instructions to the involved service partners cover
and ensure the following elements :
10.2.1.a - receiving and forwarding shipping instructions ? I
10.2.1b - receiving shipping and/or storage instructions ? I
10.2.1c - issuing customs documentation ? I
10.2.1d - obtaining the Bill of Lading ? I
10.2.1e - preparation of a hazardous cargo booking list (HBL) ? I
10.2.1f - collection of Dangerous Goods Declaration (DGD) ? I
10.2.1g - issuing the relevant shipping documents such as DGD to the shipping agent ? I
10.2.1h - producing and issuing the Bill of Lading, when authorized ? I
10.2.1i - providing all applicable information to the forwarding agent in order to produce the Bill of Lading I
(when company is not authorized to produce the BOL itself) ?
10.2.1j - advising the shipping agent about cargo with special requirements (such as deck stowage, I
heating/cooling requirements, etc) ?
10.2.1k - is arrival / departure time recorded for individual transit legs ? I
10.2.1l - is tracking and tracing available during the movement of the tank/tank container ? I
10.3 Tank Cleaning
10.3.1 Have all cleaning stations of tanks/tank containers been assessed against SQAS for Cleaning Stations I RC
(or equivalent assessment system) ?
10.3.2 Has the company analysed the assessment reports of the used cleaning stations and agreed an I RC
improvement action plan with defined responsibilities ?
10.3.3 Is it ensured that all cleaning stations have permits for the products cleaned ? M RC
10.3.4 Are clear instructions given as to which third party cleaning stations are to be used ? I RC

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations Y N N/A cat

10.4 Driver instructions (Driver Manual issued by Intermodal operator)


10.4.1 Is there a drivers manual distributed to all drivers in a language they can understand ? I
10.4.2 Does the drivers manual contain detailed instructions regarding :
10.4.2a - BBS principles ? RC
10.4.2b - incident reporting ? I RC
10.4.2c - near miss reporting ? I RC
10.4.2d - use of seat belt ? I RC
10.4.2e - use of mobile phone ? I RC
10.4.2f - use of drugs and alcohol ? I RC
10.4.2g - actions to be taken in an emergency ? I RC
10.4.2h - security ? I RC
10.4.2i - identification of the product ? I RC
10.4.2j - inspection prior to loading ? I RC
10.4.2k - loading procedures ? I RC
10.4.2l - visual inspection of tanks, valves and hoses for cleanliness? I RC
10.4.2m - correct hose connection and valve operation ? I RC
10.4.2n - correct operation of any transfer equipment ? I RC
10.4.2o - equipotential electrostatic bonding/earthing ? I RC
10.4.2p - verification that all prescribed documentation, including the written instructions for drivers M RC
(transport emergency cards), is on board of the transport unit ?
10.4.2q - verification of the presence of all the (safety) equipment as required by legislation and prescribed M RC
in the written instructions for the drivers (ADR goods) ?
10.4.2r - after loading, verification that vehicle and loads have no obvious defects, leakages, cracks, I RC
missing equipment ?
10.4.2s - after loading, verification that danger labels and markings (orange plates) prescribed for the M RC
vehicles, have been affixed (ADR and IMDG goods) ?
10.4.2t - compliance with route restrictions for specific products ? I RC
10.4.2u - operating/driving restrictions during bad weather conditions ? I RC
10.4.2v - unloading procedures ? I RC
10.4.2w - observation of instructions/practices at loading and unloading sites (regarding working on height, I RC
safe tank entry procedure, safe sampling practices) ?
10.4.2x - use of wheel blocks (to avoid uncontrolled vehicle movement) ? I RC
10.4.2y - cleaning stations to be used ? I RC
10.4.2z - visual inspection of tanks/tank containers, valves and hoses for cleanliness ? I RC
10.4.2aa - correct hose connection and valve operation ? I RC
10.4.2bb - correct operation of any transfer equipment ? I RC
10.4.2cc - equipotential electrostatic bonding/earthing ? I RC
10.4.2dd - sampling responsibilities and safe sampling practices ? I RC

10.4.3 Is there a check on gaskets and seals prior to use ? I RC

10.4.4 Does the drivers manual contain, in addition, specific detailed instructions for PACKAGED GOODS
regarding :
10.4.4a - inspection of cargo compartment for cleanliness and potential risks (e.g. nails) ? I RC
10.4.4b - stowage and cargo securing ? I RC
10.4.4c - product compatibility and segregation ? I RC

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Section 11 Administration
IMPCAS Specific Questions
11.1 Records Y N N/A cat

11.1 Records
11.1.1 Are records of all transport orders (receipts and deliveries) kept, including :

11.1.1a - order identification ? I


11.1.1b - tank/tank container identification and job number ? I
11.1.1c - requested loading date, loading time and loading site ? I
11.1.1d - actual loading date, loading time and loading site ? I
11.1.1e - quantity received and delivered ? I
11.1.1f - requested delivery date, delivery time and delivery site ? I
11.1.1g - actual delivery date, delivery time and delivery address ? I
11.1.1h - cleaning documents/certificates ? I

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Section 12 Site Inspection
IMPCAS Specific Questions
12 Site Inspection Y N N/A cat

12.1 Office and Buildings


12.1.1 Is the visible condition of the buildings of an acceptable standard ? I
12.1.2 Is housekeeping at a good standard (clean, tidy, paintwork, etc.) ? I
12.1.3 Are emergency exits marked on buildings and unblocked ? M
12.1.4 Are signs for site identification and public safety in place ? I
12.1.5 In case of emergency, is there an assured method for safe evacuation of all personnel and is this M
publicly placarded ?
12.1.6 Is the emergency assembly point clearly placarded ? M
12.1.7 Are fire extinguishers marked with the inspection and maintenance data ? M
12.1.8 Are the first aid posts clearly indicated, easily accessible and appropriately stocked to ensure prompt M
treatment ?
12.1.9 Is there a sufficient site lighting system ? I
12.2 Depot and Parking
12.2.1 Is the site paved according to the requirements and the activities that are taking place ? I
12.2.2 Is the condition of roadways and parking area of an acceptable and safe standard ? I
12.2.3 Are there designated walkways away from truck traffic ? I
12.2.4 Is the site location suitable for vehicle access and is there easy movement of trucks around the site ? I
12.2.5 If loaded trailers are parked at the site, are landing gear support pads used when there are I
weaknesses in the parking surface ?

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Section 13 Tank containers
IMPCAS Specific Questions
13.1 Associated Equipment Y N N/A cat

13.1 Associated Equipment


13.1.1 Are the following items and equipment of an acceptable standard :
13.1.1a - condition of cargo compartment/container ? I
13.1.1b - condition of cargo securing devices ? I
13.1.1c - condition of earthing point ? I
13.1.1d - condition of hoses (including labeling with the company name, numbering and test date) ? I
13.1.1e - condition of emergency control cable shutdown system ? I
13.1.1f - are valves and man lids of empty/clean tank containers closed ? I
13.1.2 For equipment carrying dangerous goods, are labeling, placarding and marking in conformance with M
IMDG / ADR ?

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Section 1 Tank Container Management
IMPCAS Core Questions
1.1 Management Responsibility

1.1.1 Company Policies


1.1.1.1a-g The policy statement(s) must be clear and unambiguous concerning management’s commitment to
the QHSSE & D & A which meet customer's, statutory and other requirements at all times. There
should be evidence that the policy is reviewed and kept up to date.
1.1.1.2a BBS (or an equivalent programme) aims to increase safety during transport and related
loading/unloading activities by positively influencing the behaviour of operators/drivers through
observation, coaching and communication. It is envisaged that BBS programs are an integrated part
of the company QHSSE policy. Verify if specific reference is made in the policy to Behaviour Based
Program
1.1.1.2b Verify if it is explicitly stated in the D & A policy that the use/or being under the influence of any drug
or alcohol is prohibited during working hours.
1.1.1.2c Protecting people, safeguarding the integrity of high value and hazardous products against loss by
intentional destruction or theft, and proprietary information in the custody of a logistic service provider
is essential. Verify whether the importance of these objectives are specifically mentioned in the
policy.
1.1.1.2d Is there evidence that the policy(s) are communicated to all staff and contractors and others who
need to know?
1.1.2 Roles & Responsibilities
1.1.2.1 To achieve a positive score, there will be an organisation chart for the site showing individuals' job
titles and to whom they are responsible. These titles should be supported by job descriptions which
are relevant to the work carried out. The company should have formally designated representatives
for operational safety & occupational safety & health, environmental protection, security and quality.
Where this particular question is categorised as “I” bear in mind that in some countries a Safety
Manager is a legal obligation. In a larger company these may be full-time jobs but it is recognised
that in smaller companies‚ these roles may be part of another job. The posts need not have this
particular management titles. The responsibility for the QHSSE management systems within the
Company and the responsibilities for the effective operation and maintenance of these systems
should be clearly defined and assigned.
1.1.2.2 Has local Senior. management signed off the HSSE policy statement, initiated HSE cases and set
HSSE objectives and targets? Do documents prove an active leadership by taking the lead in e.g.
presentations, interventions, discussing HSSE in staff meetings as well as with contractors?

1.1.2.3 Seek evidence in sr., middle management communication encouraging staff and contractors to also
show leadership at that level, resulting in reports regarding HSSE metrics against HSSE target like
incidents, near misses, occupational illness case analysis. Are those also consequently discussed in
the appropriate committee(s).
1.1.2.4a-d Look for documentary evidence. If a person is formally designated, this responsibility should be
clearly described in a job description. If an external source is used, there should be clear evidence
of a contract, exchange of letters or some other form of written understanding specifying the service
to be provided, when and to whom within the Company.

1.1.2.5 All companies that are engaged in the loading, transport or unloading of dangerous goods are
required to appoint a certified Dangerous Goods Adviser (DGA). Companies may appoint an
individual within their own organisation or they may use the services of an external consultant.
Check that the Company has formally appointed an individual as Dangerous Goods Adviser by
written notification. Check the validity of the Dangerous Goods Adviser's training and certification.

1.1.2.6 Check that the Dangerous Goods Adviser produces annual report in a timely manner summarising
the Company’s activities concerning the transport of dangerous goods that is in compliance with the
legal requirements. Check that the report explicitly includes security.

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Section 1 Tank Container Management
IMPCAS Core Questions
1.2 Personnel

1.2.1 Recruitment

1.2.1.1 There should be a written recruitment procedure. Give a score for each item (a - d) mentioned when
it is clearly specified in the procedure.
1.2.1.1a Verify a random sample from records.
1.2.1.1b Verify that the requirements of the job are consistent with the person's background, education,
experience, competence and knowledge of appropriate working languages. Where permitted by law,
verify that individuals' security background have been checked.
1.2.1.1c Check whether temporary staff are employed regularly or occasionally. In either case, the
recruitment policy should require the same criteria to be applied for temporary staff/drivers as for
permanent staff.
1.2.1.1d Verify a random sample from records.
1.2.1.2 Check for evidence. Keep in mind that the legal requirements might be different in some countries.
1.2.1.3 The disciplinary procedure should be a written one and communicated to all employees. Verify by
asking a sample of employees that they have been made aware of this procedure. Establish that the
procedure has been followed. Note access to confidential records may not be possible, but the
viewing records with seeing the names of individuals should be possible.

1.2.2 Training
1.2.2.1 Induction training at the commencement of employment provides new employees, part time staff
and contractors with important information about the core values, policies and procedures within the
organisation. Induction training can be expected to cover at least the following: Quality,
environmental, safety, safety and health and security and emergency response arrangements. There
should be induction training records showing who was trained, when, by whom and on what
subjects.
1.2.2.2 All managers, supervisors and operational personnel are expected to have formal training in subjects
related to their job and responsibilities. It is expected that the training requirements are reviewed on
at least an annual basis and actions taken to satisfy training needs.

1.2.2.3 a-o Check random samples of training records to confirm that the subjects mentioned are
covered.Training should include at minimum general requirements relating to the specific job
requirements
1.2.2.4 Verify that the first aid training programme is documented and implemented (including refresher
training). This may vary by country legislation.
1.2.2.5 Check that records are complete and up-to-date.
1.2.2.6 Are there sufficient persons trained and skilled for key activities to provide cover for absences; leave,
illness etc?
1.2.2.7 Verify from records.

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Section 1 Tank Container Management
IMPCAS Core Questions
1.3 QHSSE Performance Analysis

1.3 Non-conformances Reporting, Investigation, Analysis and Corrective Action


1.3.1 Data should be available at every phase of the business from identifying new business through to
customer reaction and feedback. The collection and analysis of data can indicate means of
improving the service or conversely, can detect the onset of a reduction in the quality of service
before it becomes a major issue. To verify the satisfactory operation of the reporting system, several
sources of information should be checked such as reports to insurance companies, customer
complaints and fines, feedback from internal observations (e.g. drivers).

1.3.1.1 This question (items a - j) only scores if there is a documented system in place for recording and
investigation, clarifying what is a non-conformance, who must report, how and to whom, who must
investigate and the process of follow-up and close out of corrective actions.These questions are
applicable for all domains such as environment, safety & health, security.
1.3.1.1a.b Accident : An unplanned event that did result in quality loss, injury, illness, or damage. Incident :
An unplanned event that could have resulted in quality loss, injury, illness, or damage
1.3.1.1f e.g. observed overdue implementation of new regulatory requirements, fines,
1.3.1.1g A situation or behaviour that did not result in quality loss, injury, illness, or damage, but has the
potential to do so.
1.3.1.3 Look for documentary evidence that appropriate immediate actions are taken following the issue of a
non-conformance report.
1.3.1.4 Look for documentary evidence that appropriate notifications are issued to the customer within
24hours.
1.3.1.5 For all non-conformances, a written report should be prepared for the responsible management and
the customer without undue delay and in accordance with an internal procedure, covering a - c. The
investigations into non-conformances should identify the immediate causes, the root causes and
recommended actions to prevent recurrence. Where appropriate and depending of the nature of the
non-conformance, recognised techniques should be used to identify the root causes e.g. cause tree
analysis Check a few reports from the file of completed non-conformances

1.3.2 QHSSE Trend Analysis and Improvement Objectives

1.3.2.1a-c An effective system should be in place for the recording and analysis of data, which allows identifying
trends in the number of QHSSE non-conformances. Check evidence that such a system exists. Ask
to see a summary of the trend analysis for the last year(s). If a company has already been
assessed, data should be available for the last three years, which should document continuous
improvement on the issue. If not, this question must be scored with "N".
1.3.2.5 Verify whether SHEQ&S objectives are defined and if these objectives are monitored as per defined
frequency (e.g. quarterly, annually) with actual performance data.
1.3.2.6 Verify whether QHSSE objectives are defined and if these objectives are monitored as per defined
frequency (e.g. quarterly, annually) with actual performance data.
1.3.2.7 Look for documentary evidence that annual targets have been set and that measurements of the
performance improvement against targets are being made. Also check if there is an action plan to
support and achieve the targeted improvement.
1.3.2.8 Look for documentary evidence on the effectiveness of the corrective and preventative actions

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Section 1 Tank Container Management
IMPCAS Core Questions
1.4 Management Review

1.4.1 Management Review

1.4.1.1a-d Check for evidence that a formal management review of the QHSSE management systems is held,
at least annually, to evaluate the overall effectiveness of these systems. In large companies, these
meetings may be reasonably formal with well-defined agendas, while with smaller companies it may
be less formal. Whatever the process, there must be minutes of these meetings.

1.4.1.2 It should be evidenced that interim meetings are held by responsible management to monitor the
SHQS&S matters regularly versus objectives and set targets. Verify if this is done. Take into account
that in large companies this review may be part of a formal SHQS committee which meets regularly,
while in smaller companies this may be less formal but no less effective.
1.4.1.3 Safety walk abouts are internal periodical safety inspections. (Sr)management should perform a role
model and show involvement. Therefore it is important that they participate in SHE inspections. A
walkabout every trimester is a minimum. The involvement of Sr management should be seen every
year.
1.4.2 Internal Communication

1.4.2.1 There should be a process in place between the management and employees on QHSSE to share
learning and to raise any issues of concern. Ways to achieve this may be through QHSSE meetings
or one to one discussions. Ask for objective documented evidence that feedback is shared and input
from employees is encouraged.

1.4.3 Internal Audit

1.4.3.1-3 For an effective control of the Management Systems it is necessary to audit each stage of the
management system. Such audit(s) should be thorough and comprehensive. The assessor should
look for a written audit plan indicating a detailed system. A document detailing what will be audited,
the frequency and who will do it must be available. Look specifically if the areas as referred to in
IMPCAS TCO are sufficiently covered. At least 80% of the chapters must have been subject to an
internal audit before a positive score can be given.

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Section 1 Tank Container Management
IMPCAS Core Questions
1.5 Insurance

1.5.1 Insurance

1.5.1.1a-f Verify that the company has insurance policies that meet legal and customer requirements to cover
the requirements a - f. Check the validity periods.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.1 Risk Management

2.1. Risk Management


Please note that Risk Management related to Security is covered more explicitly in section 3 and
Risk Management related to Intermodal Security is also covered in section 7.
A documented system should be in place to describe how risks associated with the companies
operations are evaluated. The risk assessment should assess the risks from both safety and health
hazards and security threats. The process should consider statutory and legislative requirements and
risks resulting from operational activities. The risk assessment and management system should
examine the following questions:
- what are the hazards?
- what can go wrong?
- what is the probability that something will go wrong?
- what is the potential impact on people, property and the environment?
- what measures should/can be taken to reduce the identified risks as much as possible?
Risk management should be regarded as a continuous process.The process should be repeated at
regular intervals, based on practical experience and incident evaluation. High risk activities should
receive more frequent reviews. A risk assessment should also be carried out each timethere is a
significant change in the operational activities (e.g. handling of new products, use of new equipment,
changes in operating procedures). New projects should be evaluated at an early stage. The risk
assessments for new projects should be carried out in close co-operation with the chemical
suppliers.
2.1.1 To score a ‘yes’, a documented system should be in place (see main comment above) to assess and
manage the risks of both existing and new operations. Check if the process of risk assessment is
repeated at regular intervals (at least annually) for existing operations and takes into account
practical experience obtained during the operations and from incident evaluations. Check if a risk
assessment has been carried out each time there has been a significant change in the operational
activities and for every new project. Check the risk assessment report of two recent new activities or
projects.
2.1.1a The auditor should identify any new products recently carried, at the same time any new routes that
products are transported over.These activities should be verified by a risk assessment.The auditor
should ask to see the DGA report (if a DGA is required) (may be separate from main DGA Annual
report) that assesses the safety and environmental impact of new products before carriage or new
services that are planned.
2.1.1b From conversation with auditees identify any work practice changes, check whether this warrants a
risk assessment to mitigate the operating risk, has a risk assessment been conducted ?

2.1.1d Look for regular reviews (minutes of meetings) or risk assessments within defined intervals.
Emphasis on environment is necessary.
2.1.1e Look for regular reviews (minutes of meetings) or risk assessments within defined intervals based on
the listed vulnerable products and logistic modes. Emphasis on security is necessary.
2.1.1f Verify the risk assessment system as well as the company’s internal computer system security, e.g.
on EDI links, order processing and use of customer order details on an Internet site.
2.1.2 Look for documentary evidence of communicated and implemented changes in the various
applicable SHEQ&Sec management system documentation and registrations.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.2 Safety

2.2.1 Personal Protective Equipment (PPE)


Please note that this section deals with PPE used by "OWN Personnel" only. The controls over PPE
of contract-personnel are covered in the section on subcontracting.
2.2.1.1 Verify that an adequate procedure exists and is implemented.
2.2.1.2 The result from equipment checking should be documented, showing the inspection date, condition,
name of the inspector and comments. The auditor should ask to see an issue register for PPE to
employees, this can then verify defective PPE equipment was repaired before issue. The register
should also show the frequency of checks on PPE to verify condition.
2.2.1.3 For some particularly hazardous substances specialised equipment is required, for example: suitable
respiratory protective devices, antidotes or decontaminants are required. Check whether an analysis
has been made on the products the company is handling and that the need for specialised
equipment has been determined. Check that instructions for use have been made available to
individuals using the equipment and any relevant training has been conducted.

2.2.1.4 Is there evidence that equipment is used?

2.2.2 and On Site and off Site Emergency & Security Preparedness and Response
2.2.3
This section evaluates the ERS capabilities of the company itself (including those organisations to
which it specifically subcontracted) and is independent of the measures and facilities that are
coordinated by the national emergency services or authorities. To achieve a positive score, the
Response Plan and the ERS capabilities of the organization must meet International Chemical
Environment (ICE) level 3 requirements for both onsite and offsite incidents. Level 3 assistance
means active assistance by competent personnel and/or equipment at the scene of the incident.
This section applies to own operations only. The controls over subcontractor activities are covered in
subcontracting. The assessor shall provide adequate comments when "off-site" is not applicable (eg
Non Asset based, office only), and score "No" (supported with adequate comments) when specific
items are not fulfilled in one of the systems, for example when they are part of the authority's scheme
and responsibility.
2.2.2.1 The written emergency plan should cover all applicable scenarios and should be regularly updated.
Check if all the described arrangements are in place. Verify if individuals understand their specific
responsibilities in case of an emergency. The emergency response plan should also contain any
customer specific contacts on a 24/7 basis. An emergency may turn into a crisis. Check that this
crisis plan which may be part of the emergency plan.
2.2.2.2a The auditor should check that responsibilities from top management down to the Incident supervisor
are clearly defined, this being to assist with clear lines of demarcation and reporting.
2.2.2.2c The auditor should ask for a register of Incident supervisors and what method is used to obtain 24/7
coverage, from this point questions should be asked of the incident supervisors onsite as to 24/7
coverage and the receipt by them of the schedule for 24/7 coverage.
2.2.2.2d The emergency response plan should detail parties to be informed in the event of an emergency,
both internally and externally.
2.2.2.3 Check that this is procedure is incorporated into the emergency plan. Look also for up to date list of
contact numbers.
2.2.2.4 Fire hoses, fire extinguishers, eye bottles, emergency showers, breathing apparatus, first aid kit
2.2.2.5 Evidence of a practical emergency exercise to test the system for on-site emergencies during the last
12 months is required.
2.2.2.6 This is a plan to ensure that operations continue in case of business disruptions
2.2.3 Off-site Emergency Preparedness and Response
2.2.3.2a-h The written emergency plan should cover all the items listed in a - k inclusive and should be regularly
updated. Check if all the described arrangements are in place. Verify if individuals understand their
specific responsibilities in case of an emergency or incident.
2.2.3.4a-d The auditor should check that the emergency equipment listed in a - d inclusive is in place, is
maintained in good condition.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.3 Occupational Health and Safety

2.3 Occupational Health and Safety


2.3.1 - 2.3.9 Check that the requirements stated in 2.3.1 - 2.3.9 inclusive are adequately addressed. Where
necessary samples should be selected
2.3.2 A product acceptance procedure should be in place asking for the product safety data before the
product is handled. Product safety data should be supplied by the manufacturer. Check the
accessibility of this information at the site (e.g. a file with the Safety Data Sheets of all the products
transported or handled). Check at random the available information for a few products.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.4 Environment

2.4. Environment
2.4.1- 2.4.5 Check that the requirements stated in 2.4.1 - 2.4.5 inclusive are adequately addressed. Where
necessary samples should be selected.

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Section 2 Safety, Health, Security and Environment
IMPCAS Core Questions
2.5 Spill Prevention and Control

2.5 Spill Prevention and Control

2.5.1a - c Check that the requirements stated in 2.5.1a-c inclusive are adequately addressed. Where
necessary samples should be selected

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Section 3 Security
IMPCAS Core Questions
3 Security

3.1 Security standards and procedures


3.1.1 Verify that the company has appointed a competent person with appropriate qualifications with the
necessary authority to act as the responsible person for security.
3.1.2 Has the company developed a security plan, based on its security risk assessment, which includes
all ADR/IMDG requirements and implemented security arrangements such as those in ISO/PAS
28000, WCO Framework of Standards and other requirements to which the organisation subscribes.
3.1.3a-d Does the company Security Plan include :
- a regular review of the operations and an assessment of potential vulnerabilities including :
- measures identified / taken to reduce security risk
- reporting system must be in place for security threats and for security related Near Miss / Incident
reporting .
- security must be integrated in the regular training sessions.
- look for an annual review report, including evaluation and test results.

3.2 Site security


3.2.1 Check fences, gates and 24hr lighting during your site visit. Establish that physical barriers serve the
purpose they are designed for.
3.2.2 Give a score for any effective control method, e.g. security guard, electronic card entry system, etc.
3.2.3 Check the availability and the use of periodic inspection sheets or security check lists and verify the
reporting of incidents and its remediation.
3.2.4 Check the internal system that vehicle movements are controlled within the site.
3.2.5 Verify the company’s internal computer system security, e.g. on EDI links, order processing and use
of customer order details on an Internet site.
3.2.6 Verify adequate manning levels

Note: When the assessed site is part of a shared port facility, a comment should be provided
when this requirement cannot be met. In this case the organisation being audited shall be
expected to declare how security threats form neighbouring facilities are catered for.

3.3 Security Training


3.3.1. There must be a list of all personnel that require security training. The nature of the security
knowledge to be covered by the training must be in line with the HCDG plan and security risk
assessment. The auditor should recognise that the training required will depend on the vulnerability
of the site, the nature of the threats and goods being shipped. The competence, experience and
security training required will reflect this. The minimum training, however, should include the
requirements in 3.3.1a - f inclusive.

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Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care®

4.1 Quality System


4.1.1 The Quality System, operated by the company must be documented. This documentation is
important for controlling quality. The QS documentation should, as a minimum, comply with the
requirements of ISO 9001:2000. For a company being certified against ISO 9001:2008 the Auditor
should convince themselves that the scope of the certification covers all relevant processes and that
the depth of the system is adequate.

4.1.2 a - k It is essential that the Quality System is studied in detail, to establish that it covers the items listed.
Evidence of each item to be seen and only marked as “Yes” if present in the Manual (or next layer
documentation) and is being used.

4.2 Purchasing of critical Materials and Services


4.2.1 Select a sample of purchase orders to verify conformance with this requirements

4.3 Control of purchased materials and services


Note: The use of contractors by the Operator may be critical to cost, efficiency and safety of the
service provided. The procurement of products or services should be given the same level of
planning and control as internal activities.
4.3.1 Confirm by tracing at random how suppliers of equipment and/or services have been selected.
Examples should be taken at random and checked.
4.3.2 Verify that an adequate goods inspection process is in place and implemented which reflects the
criticality of goods. Examples should be taken at random and checked.

4.4 Suppliers of critical goods and services


4.4.1 The auditor should check that any recorded non conformances are investigated as per Section 1.3.

4.5 Contacts
4.5.1 Verify that a contingency exists and look for examples of sickness, leave etc where replacements
staff/operatives have been used.

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Section 4 QMS and Responsible Care®
IMPCAS Core Questions
4 QMS and Responsible Care®

4.6 Responsible Care®

Note: Question range 4.6 is only applicable to companies seeking compliance verification with the
Amercan Chemistry Council Responsible Care Management System® Technical
Specification. For all other companies, the entire section can be answered as N/A.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.1 Choice of logistic solutions

5.1 Choice of Logistics Solutions


5.1.1 Look for a documented process including a risk assessment covering SHEQ&Sec elements, for
defining and choosing the logistics solution for the assigned "Transport Service" orders. Verify a
sample of current or completed assignments, the process for selecting the parties and persons
involved, communication lines and interfaces, schedules and routes, alternative solutions with
considerations on SHEQ&Sec requirements. This may include choice of transport mode (road, rail,
barge, sea, air) and respective means of transport (MOT) like type of containment and equipment.

5.1.2a-d For this sample of transactions, look for a risk analysis covering the relevant QHSSE elements.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.2 Supply Chain Management

5.2 Supply Chain Management


5.2.1a-d Verify through a sample of transactions that QHSSE objectives have been set and formally
communicated to all partners. Look for evidence from meetings and communications that all
providers involved in the supply chain have been considered. This includes carriers of all modes of
transport, pre- and onward carriage and any partner in charge of handling and transhipment.
5.2.2 Look for documentary evidence that company's supply chain partners' objectives and targets have
been achieved within the required timescales.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.3 Supply Chain Integrity

5.3 Supply Chain Integrity


5.3.1 Verify through a sample of transactions how the company traces and follows current status/location
during transport and transit. In larger companies, effective control of the status of shipments along
the supply chain could be based on IT-technologies like barcodes, RFID (Radio Frequency
Identification) or SCEM (Supply Chain Event Management). Look whether the process description
covers the complete supply chain.
5.3.2 Verify how the company transmits customer instructions to its partner and subcontracted service
providers. Look for evidence that all logistic partners involved in the business are informed
accordingly about the customer's requirements. E.g. verify that signed requirement profiles have
been relayed to all.
5.3.3 Look for a formal reporting process for on time - in full (OT/IF) delivery. Follow up a sample of
changes to verify that changes requested by logistics chain partners have been reviewed and
implemented.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.4 Subcontracting Services

5.4.1 Subcontracting policy

5.4.1.2 It is of critical importance that any service which is subcontracted to another operator is operated to
equivalent safety and quality standards as that of the main contractor. The auditor should verify that
these imperatives are adequately carried out.
5.4.1.3 - 4 The subcontracting policy shall describe the process for selecting subcontractors and should clearly
state that any other transport services will not be subcontracted until the subcontractors' QHSSE
management system have been assessed and judged to be of a acceptable standard to that of the
contracting logistics chain supplier. The agreements with subcontractors should state the conditions
for ongoing assessment of the sub-contractors' performance and there should be evidence that the
company carry out these assessments. The agreement should take into account any reasonable
restrictions defined by the customers. Only one level of sub-contracting is allowed unless explicitly
agreed otherwise with the customer (I.E. no sub-sub-contracting).

5.4.2 Appointed subcontractors


5.4.2.1 Verify, by sample of current transport orders, that all logistics providers are listed on the approved
suppliers list.
5.4.2.2 Are the obligations placed on logistics partners (e.g. other intermodal operators to whom the
movement of goods is subcontracted) clearly communicated in written agreements with those
partners?
5.4.2.3 All drivers, whether subcontractors or not, shall be trained by their employer or the main contractor
(the company). Evidence of training in accordance with other requirements in this documents shall
be verified.
5.4.2.4 Look for proof (documentation) that all driver's, whether subcontractors or not, shall receive a
manual that meets the requirements of the main contractor (the company). Verify the handbook's
presence when you meet some drivers.
5.4.3 Unplanned spot services by subcontractors
5.4.3.1 Spot subcontracting is defined as sudden calls upon an unknown subcontractor from the "yellow
pages". Verify that spot subcontracting is not practiced in the base-case, by comparing actual
transport orders with the list of approved subcontractors. Exceptionally, when spot subcontracting
has been used for peak demands or special orders, there must be a specific agreement from the
customer Chemical Company. Look for evidence that the minimum requirements have been
communicated and verified.

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Section 5 Supply Chain Management and Subcontracting
IMPCAS Specific Questions
5.5 Performance monitoring of logistics partners

5.5.1 Performance criteria


5.5.1.1a - s Review a sample of subcontractors' files and check that the requirements are contained in logistics
service providers' (subcontractors') service agreements.
5.5.1.2a - e Flexible hoses are critical equipment as hose breaks could cause severe health and environmental
damage.All hoses should be uniquely identified, labelled and inventorized in a database to facilitate a
maintenance/testing programme and follow-up. Verify the testing procedure and score a "Yes" for
each item reflected in the written procedure and check also whether implemented.

5.5.2 Performance monitoring process


5.5.2.1-3 For a sample of logistics partners select some evaluation and performance reports and look for
evidence that these have been evaluated. Establish that dialogue/communications have, and
continue to take place to ensure improvement actions are implemented and monitored. Look for
evidence that the company has analyzed its partners' reports from the CDI/SQAS databases or
alternatively has obtained extracted reports directly from the assessed companies.

5.5.2.4 Review a sample of agreements and verify that these include a clause giving the company the right
to carry out on site QHSSE assessments.

5.5.2.5a-b Compliance with the evaluation criteria as described in 5.5.1 should be checked before agreements
are signed and be monitored at least on an annual basis. Check for documented evidence that
performance monitoring has taken place by reviewing the CDI/SQAS assessments of these logistics
service providers or by direct auditing.
5.5.2.6 Check for evidence through meeting reports and follow-up on agreed action programmes. These
meetings should be held on a regular basis, in accordance with the level of business involved.

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Section 6 Equipment
IMPCAS Specific Questions
6.1 Equipment Specification

6.1 Equipment Specification


6.1.1 Look for a written procedure describing the purchase/lease for equipment to ensure it includes a
requirement for standardised technical specification for each type of equipment including references
to any relevant regulatory standards.
6.1.3a-c Check the specifications for a sample of recently purchased/leased equipment to verify that they
include the necessary specifications as detailed in 6.1.2a - c inclusive

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Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance and Calibration

Note: Questions 6.2.2.3a-c & 6.2.2.4 are ''I'' (industry) questions marked as ''M'' (mandatory) to fullfill the
requirements for the compliance facility for tank examination and testing.

6.2.1 Equipment Inspection and Maintenance (Service)


6.2.1.1a-d Verify that there is a documented programme for inspection, maintenance and calibration of
equipment described in 6.2.1.1a - d inclusive.
6.2.1.2a-d Check for a clearly documented procedure addressing each of these questions. Verify that the
documented procedure is being implemented for equipment found to be non conforming, particularly
those items which have been put into service or used with faults or overdue for inspection. This
procedure should include the corrective actions to be taken when non conforming equipment is used.

6.2.1.3 Check for the most recent service items and dates.
6.2.1.3a Check access to central file.
6.2.1.4 Check for the most recent service items and dates.
6.2.1.5a-f Check each service item is addressed.
6.2.1.6a-f Check for each type of unit, answering N/A when units are not used by the operator.

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Section 6 Equipment
IMPCAS Specific Questions
6.2 Equipment Inspection, Maintenance and Calibration

6.2.2 Statutory Examination and Testing


6.2.2.1 Check documented procedure clearly references the CSC.
6.2.2.2 Check records of test certificates for dates of most recent examinations and tests.
6.2.2.3 a-c Answer ''YES'' for either PES or ACEP or if individual certificates are posted to IMPCAS. A ''NO''
answer to all three questions would signify non-compliance. Note: The IMPCAS facility is intended
for smaller companies not operating PES or ACEP for a small number of tank conatainers.
6.2.2.4 a-b Check access to local and corporate facility.
6.2.2.5 a-k Verify from check lists or as items on the computer program or from test certification.
6.2.2.6 & 7 Check Management System for this procedure. Note: A portable tank may not be filled and offered
for transport after the date of expiry of the last 5-year or 2.5-year periodic inspection and test as
required by the IMDG Code. However, a portable tank filled prior to the date of expiry of the last
periodic inspection and test may be transported for a period not to exceed three months beyond the
date of expiry of the last periodic test or inspection. In addition, a portable tank may be transported
after the date of expiry of the last periodic test and inspection:
1. after emptying but before cleaning, for purposes of performing the next required test or inspection
prior to refilling; and
2. unless otherwise approved by the competent authority, for a period not to exceed six months
beyond the date of expiry of the last periodic test or inspection, in order to allow the return of
dangerous goods for proper disposal or recycling. Reference to this exemption shall be mentioned in
the transport document.
6.2.3 Identification and Calibration of Measuring & Test Equipment
6.2.3.1 Calibration, if performed in-house, should be undertaken by persons who have been properly trained
and are working to documented procedures. Alternatively, calibration may be undertaken by a
qualified contractor certificated to national standards. In this case, a formal agreement specifying the
requirement for, and the frequency of, calibration should exist between the operator and the
contractor. Ask to see a copy of the procedures and a list of items identified for calibration.

6.2.3.2a-e Verify that records confirm calibration has been carried out in accordance with applicable legislation.

6.2.3.3 Verify that records are maintained and are consistent with the calibration equipment being used.

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Section 6 Equipment
IMPCAS Specific Questions
6.3 Equipment of Partners

Note: In following questions, the assessor judges the compliance based on reasonableness (80/20
rule), meaning that he reviews the key logistics partner(s) engaged by the company.

6.3 Equipment of Partners


6.3.1 Look for evidence from assessments and visit reports that the sampled subcontractors have adopted
the statutory requirements and industry standards (as specified in the purchase specification of
section 6).
6.3.2-5 Look for evidence from assessments and visit reports.

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Section 7 Behaviour Based Safety (or equivalent programme)
IMPCAS Specific Questions
7.1 Service Partners Awareness

Note: Behaviour Based Safety (BBS or equivalent programme)


When an equivalent system from BBS is used by the company, all requirements/objectives,
as documented in the Cefic/ECTA guidelines on BBS must be verified and met, in order to
score positive.
7.1 Service Partners Awareness

7.1.1 Verify that the company implements the principles of Behaviour Based Safety (BBS) or equivalent
programme for vehicle driving and loading/unloading. Check that this is implemented for the
company's own and its service partners operatives.
7.1.2 Management should set targets in relation to the implementation and results of the BBS program .
7.1.3 Check for a project file with documented implementation plan and up to date status.
7.1.4 Look for role descriptions referring to the following responsibilities in relation to BBS. Management
are mainly responsible for the implementation and ongoing support of the BBS program. They should
have defined roles, delivered resources, and removed barriers to a successful implementation which
result is monitored against targets. Dispatchers / planners should understand and support the BBS
program in order to avoid / eliminate planning and instructions which may be in conflict with the BBS
principles. Trainers do not only execute the BBS training but they also collect data and report the
results to management. All staff should understand the purpose of the BBS program, be positively
committed to participate and accept preventative changes as a result of the BBS findings and
analysis
7.1.6 Check for progress reports.
7.1.7 Are key performance indicators identified and measured.
7.1.7a Check the training programme and the individual driver records,.
7.1.7b Check the training programme and the individual driver records.
7.1.7c Check the training programme and the individual driver records.
7.1.7d Related to individual driver records if applicable. Dedicated transports.
7.1.7e Check if process is in place and if files are available.
7.1.8 Verify that the company implemented this requirement.

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Section 8 Intermodal Security
IMPCAS Specific Questions
8 Intermodal Security

8.1 Security Plan


8.1.1 Check that the company gives its logistics service providers (subcontractors) the information
necessary for it to carry out the contracted service and ask how instructions are communicated to
whilst retaining the necessary level of confidentiality.

Check contracts with service partners, selected form the approved suppliers' list, for security
8.1.2a-d clauses, requirements, etc, as detailed in 8.1.1a - e inclusive.
Check for documented evidence. As an example an EIR (Equipment Interchange Receipt?) could be
used.

8.1.3 Verify by taking samples.

Security during intermodal transport moves

8.2 Interview a selection of operatives. Verify that the both company's and their subcontractors'
operatives comply with their company's procedures which in turn shall comply with ADR/IMDG

8.3 Legal requirements for High Consequence Dangerous Goods (HCDG) :

8.3.1 Check from recent transactions, whether High Consequence Dangerous Goods are being
transported. If so the tankcontainer operator's security plan shall meet the requirements of both
IMDG and ADR.

8.4 Best practices for transport security of HCDG :

8.4.1 Verify that arrangements are in place and are adequate for tracking and tracing HCDG while in
transit. Arrangements could include GPS tracking, periodical contacts, Internet connection, etc.
8.4.2 Look for sealing procedure and unique numbered seals recorded on transport documentation. Check
that the practices on sealing by interviewing personnel for their understanding of these arrangements
and verify that instructions are being implemented.
8.4.3 A reporting system for seal discrepancies must be in place, including investigation and follow-up.

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.1 Operating instructions

9.1 Operating Instructions


9.1.1 The site should have all the necessary operating and environmental licenses for all the activities
carried out at the site including, but not limited to: fuel facilities, maintenance workshop, parking of
trucks, temporary storage of goods, etc. The assessor will check the available licenses against the
site’s activities.

9.1.2 This question (items a -i) only scores if there is a documented system in place and implemented, for
defining, recording and investigating non conformances, including by whom, how, what and when,
and the process of follow-up and close out of corrective actions.
9.1.3 Check for each work permit or procedure if the requirements are clearly identified. Check if the work
permit system or procedures are implemented as required in 9.1.3a - 9.1.3d.

9.1.4 The auditor should look for operating procedures and instructions that cover clean up and disposal of
spillages, as required in 9.1.4a - 9.1.4c inclusive.

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Section 9 Site Operating Procedures and Customer Interface
IMPCAS Specific Questions
9.2 Customer Interface

9.2 Customer Interface

9.2.1 Select a sample of transactions for loading between the company and their customers (chemical
companies) and verify that the requirements in 9.2.1a - 9.2.1o inclusive are clearly stated and are
being implemented. Note these checks should include auditing the information in transport
movement orders and driver's handbooks.

9.2.2 Select a sample of transactions for loading between the company and their customers (chemical
companies) and verify that the requirements in 9.2.1a - 9.2.1h inclusive are clearly stated and are
being implemented. Note these checks should include auditing the information in transport
movement orders and driver's handbooks.

9.2.5 a & b Verify a sample of customers and check that meeting take place and actions are completed.

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations

10.1 Order Planning


10.1.1 The assessor should review the documented procedures and give a positive score if the key
elements are covered, e.g. equipment maintenance schedules are not conflicting with order
execution schedules.
10.1.2 Verify by reviewing relevant information and instructions, detailed in 10.1.2a - 10.1.2i.

10.2 Order instructions for multimodal shipments


10.2.1 Check documented procedures and look for evidence that the multimodal operations are handled,
planned and controlled as per conditions required in 10.1.2.1a - 10.1.2.1l

10.3 Tank Cleaning


10.3.1 There must be evidence of a list of approved cleaning stations. This approved list should contain
current assessed and approved stations. For cleaning stations outside Europe a similar
audit/assessment system to SQAS should be in place for each location. Evidence must be available
that the company has made an assessment of the SQAS or equivalent audit reports and has
confirmed that the cleaning station has achieved a satisfactory result. If the company operates their
own cleaning facilities these must also meet current SQAS audit requirements or equivalent.

10.3.2 Where there are deficiencies against the company criteria, there should be a written and agreed
improvement plan. There must be evidence that the company is following up on these action plans.
10.3.3 Evidence must be available that cleaning stations have the necessary permits for the groups/types of
products handled.
10.3.4 Verify by looking for instructions given to hauliers.

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Section 10 Order Process and Operations
IMPCAS Specific Questions
10 Order Process and Operations

10.4 Driver instructions (Driver Manual issued by Intermodal operator)

10.4.1 Check if drivers manual are produced and distributed to all drivers in a language they can
understand. Take a random check by asking 2 or more drivers if the manual is present. Examine
selected instructions to check that details are up-to-date. The score is “No” if significant details are
out of date.
10.4.2a-dd Scores a "Yes" for each listed item for which an instruction exists that covers critical SHEQ&S
aspects.Check that the drivers manual is up-to-date by checking references to updates in
ADR/IMDG and/or other applicable legislation and developments. Verify a sample of driver's
handbooks that the information in 10.4.3a - 10.4.3dd inclusive has been included.

10.4.4a-c Scores a "Yes" for each listed item for which an instruction exists that covers critical SHEQ&S
aspects.
10.4.4b Do the instructions cover the preferred method for securing palleted items, octabins or bags and
does it also specify the use of dunnage.

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Section 11 Administration
IMPCAS Specific Questions
11.1 Records

11.1 Records
11.1.1 Pick several deliveries at random. Score a "Yes" for each of the listed items if the requirements in
11.1.1a - 11.1.1h have been adequately covered

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Section 12 Site Inspection
IMPCAS Specific Questions
12 Site Inspection

Note This section covers the physical inspection, by the assessor, outside on the site of the
assessed company.

An effective system of management will be reflected in the site e.g. its content, layout,
condition and modus operandi. The scope of the site inspection should cover the office
buildings, maintenance workshop, parking, fuel station. Any bulk storage of products from
customers.

12.1 Office, buildings and site in general


When the company is only operating an office building, the site inspection is limited to sub-section
12.1.1 - 12.1.9 and the remainder of Section 12 may not be applicable. Otherwise, the "office and
site" questions refer to all buildings/infrastructure of the site.
12.1.1 - 9 Verify by conducting a site tour.

12.2 Depot and parking


12.2.1 Check that all site surfaces where product/equipment handling and movement take place, are made
of stable materials (bricks, concrete, asphalted, etc to avoid holes that could cause safety hazards).
Where hazardous liquids are handled the surface should be impervious.

12.2.2 The condition of the fences, gates, roadways, parking areas and buildings gives an indication on how
seriously the site management is interested in quality and safe operation, and not only in commercial
affairs. This is also important for the image of the company. Look for example if there are potholes
or flakes of water on the parking areas.
12.2.3 Walkways prevent uncontrolled traffic flow on the site and protect walking people by organised
routes on the site. They should be marked out as a permanent feature.

12.2.4 The access to the site should be such that no safety hazard is caused to other traffic (good
visibility/no narrow streets). The traffic flow on the site should be logical, transparent and free
flowing.
12.2.5 If parking of loaded trailers on the site property is allowed, it should be done properly using support
pads to prevent landing gear pushing through any weakness in the road surface and resulting in
trailer tip-over.

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Section 13 Tankcontainers
IMPCAS Specific Questions
13.1 Tankcontainers and other associated equipment

Note: When operational equipment available on or near the site, the assessor must include a
sample check of some equipment during the site inspection, and always document the
references in the report, such that the reader has an idea of the type and number of
equipment that was checked.
13.1 Associated Equipment
13.1.1a - f At some stage during the assessment, the assessor should select at random two or more pieces of
equipment and check these against the items listed. If possible this should be equipment, which has
just returned to the site after completing an order, so that the assessor can interview the driver as
well as inspect the equipment.

13.1.2 For equipment carrying dangerous goods verify compliance with ADR/IMDG requirements including
correct labels placarding.

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Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 80 of 80

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