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TCO Nov-2010, RCMS
TCO Nov-2010, RCMS
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
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.
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
B. Audit Summary
Sect 3 Security
3.1 Security Standards and Procedures
3.2 Site Security
3.3 Security Training
TCO Introduction
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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 11 Administration
11.1 Records
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
Rev: IMPCAS 11/2010 (C)2010 Chemical Distribution Institute 5 of 80
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
TCO Introduction
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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
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
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.
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.
TCO Introduction
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IMPCAS
Tank Container Questionnaire
List of Abbreviations
This List of Abbreviations provides a summary of the standard acronyms and abbreviations.
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
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
M Mandatory
MPC Marine Pack Cargo
RC Responsible Care
RID Regulations Concerning the international carriage of dangerous goods by rail.
UN United Nations
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Section A GENERAL INFORMATION
Audited By :- __________________________________________________(Name)
Company information :-
Address:-
Tel:-_____________________________ Fax:-____________________________
Contact Person(s) :-
Name :-
E-Mail :-
Name :-
E-Mail :-
Branch Offices:-
Address:-
Address:-
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.
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.
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.
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 ?
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
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
1.3.2.2 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 ?
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
1.5.1 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
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
2.2.3.3 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
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
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
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?
5.2.2 Does the company follow-up the service providers' actions to ensure achievement of the targets ? I 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
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
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
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
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
11.1 Records
11.1.1 Are records of all transport orders (receipts and deliveries) kept, including :
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.
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.
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
1.3.2.1a-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
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.
1.4.3.1-3 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.
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.
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.
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.
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.
2.5.1a - c Check that the requirements stated in 2.5.1a-c inclusive are adequately addressed. Where
necessary samples should be selected
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.
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.
4.5 Contacts
4.5.1 Verify that a contingency exists and look for examples of sickness, leave etc where replacements
staff/operatives have been used.
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.
5.1.2a-d For this sample of transactions, look for a risk analysis covering the relevant QHSSE elements.
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).
5.5.2.4 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.
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.
6.2.1.3 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.
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.
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.
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.
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.
8.2 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
8.3.1 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.
8.4.1 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.
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.
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.
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.
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.
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
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.
12.2.2 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.
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.