STUDENT ID #: 413
PROBLEM AREA THREE – TOXIC ENVIRONMENTAL EXPOSURE
QUESTION ONE
Framing the issue: the Bhopal Gas Tragedy
The year 1984 represents a tragic and important milestone in the environmental health
arena, particularly with reference to toxic environmental exposure. At around 1AM on
December 3rd that year, more than 40 tons of methyl isocyanate (MIC) gas leaked from a
pesticide plant owned by the US-based multinational Union Carbide Corporation (UCC) in the
small city of Bhopal, India (see maps, Appendix 1). Deadly MIC gas seeped silently across the
city, exposing more than half of its population of 900,000, and immediately killing an estimated
3,800 (1). A range of effects has been reported in the aftermath: respiratory, ocular,
gastrointestinal, and neurobehavioral disorders were seen immediately (2,3), while in recent
years, genetic and reproductive health-related abnormalities have been reported (4-8). The
Bhopal Gas Tragedy is the worst industrial disaster of all time.
In 1985, as Indian authorities, activists, and survivors navigated uncharted political and
legal terrain to hold the US-based Union Carbide accountable, the company’s sister plant located
in West Virginia lost over 100 workers in a similar poisoning incident (9). The US response to
this domestic incident was expedient: in 1986 the US Emergency Planning and Community
Right to Know Act (EPCRA) was passed, giving the public access to extensive data on toxic
chemical release and exposure (10). This acted as a gateway for many more hazard safety
initiatives related to chemical exposure nationally and internationally (11-13). Yet the success of
such safeguards in preventing toxic chemical exposure is questionable: a recent study found that
chemical exposure constitutes the highest (28.6%) proportion of exposure incidents from 1996 to
2001 (14) and the National Response Center reports a 25% increase in the number of chemical
exposure incidents between 1997 and 2004 (15).
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This public health analysis is concerned with those affected by or at risk for toxic
environmental exposure specifically from the US chemical industry1. This population typically
lives near and in most cases concurrently works for the industry. Exposure to environmental
toxins in this scenario is affected by an intricate and dynamic combination of determinants.
These determinants, furthermore, vary in their relative and cumulative effect across a spectrum
of stakeholders, including populations at risk for chemical exposure, chemical corporations, state
and national governments, international and UN agencies, and others (discussed later).
Social inequality and environmental health determinants
Stark differentials exist in access to financial, legal, political, and economic resources
between the various stakeholders in this problem. Acknowledging these social inequalities, this
analysis adapts Schulz and Northridge’s 2004 conceptual framework of “social determinants of
health and environmental health promotion” (see Figure 1, below) (16). The next few paragraphs
justify this model of health, describe key determinants comprising it, and indicate the most
important one for the target populations in question.
Social inequality models for public health have long been researched and advocated for
(17-22). They are of special relevance in this context because of the role that the corporate
industry – especially chemical multinationals- play in exacerbating health inequalities within and
between nations (23-26). Schulz and Northridge’s model sees social inequalities as both
resulting in and being a result of disparities in exposure (16)p. 455). Their model depicts a
dynamic interplay of fundamental2 (such as natural environment, macrosocial factors, and
inequalities), intermediate (such as the built environment and social context), and proximate
1
The chemical industry is the US’ is the world’s largest (responsible for almost a third of the world’s chemicals
production), generating over $91 billion dollars a year in export revenue (46).
2
Analogous to, but not synonymous with Link and Phelan’s notion of social conditions as fundamental causes of
disease (74)
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determinants (such as stressors, behaviors, social integration, and social support) that operate
through multiple pathways and mechanisms to influence health outcomes. Figure 1 below
presents an adapted version of the Schulz and Northridge model guiding this analysis.
FIGURE 1. DETERMINANTS OF TOXIC ENVIRONMENTAL EXPOSURE
The determinants of toxic environmental exposure are closely related across individual,
social/cultural, political, and economic factors and often difficult to distinguish from each other.
A better frame of analysis than looking at the determinants separately is considering their
relationship to each other. There is global evidence for the differential effect of chemical
exposure by gender and age: women and children have worse health outcomes (27-32). This
differential effect is not only a function of biology, but also inequalities at other levels involving
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an interplay of social, economic, and political factors. For example, research on lead exposure in
American children reveals the contribution of socio-economic status (social context, intermediate
level) and residence in central-city areas (built environment, intermediate level) through putative
pathways of immuno-compromized nutrition (health behavior, proximate level) and greater
incidence of exposure (stressors, proximate level) (33,34). Consistent with this literature, studies
have found that at the intermediate level, enforcing housing policy to prevent lead poisoning and
increasing educational and employment opportunities for poor families (both social context,
intermediate level) may be effective in reducing lead poisoning rates (16,35).
In Cato-Ridge, South Africa, UK-based Thor Chemical’s 1992 mercury exposure
incident resulted in three deaths and acute neurobiological morbidity in over two dozen young,
poor, black South Africans (36). Here, the lack of industrial monitoring and oversight in
government policy at the proximate level had to do with political flux at the end of apartheid,
where macrosocial factors such as racism and market pressures at the fundamental level. This
resulted in unjust and unequal policy formation and enforcement, creating greater exposure risk
and an accountability vacuum (28). These examples and all other evidence point to one key
element affecting all determinants: the unequal distribution of power and health. The most
important determinant, then, is that which enables public health to redistribute unequal power
and health among stakeholders.
Industrial Codes at the Intermediate Level: Creating a Public Health bridge for equity
As the aforementioned mercury and lead case demonstrate, macrosocial factors are at the
root of inequality; they trigger risk along contextual and behavioral factor-driven pathways. As
such, they are the most influential. Yet, these determinants are also the most difficult to
influence. Interventions at the fundamental level entail changes in political or economic order
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that are typically beyond the scope of public health. On the other hand, public health
interventions have historically focused on reducing effects post-exposure (i.e. at the proximate or
outcome level) (5,37-39). These interventions have had limited success because proximate level
factors typically cannot prevent exposure incidents from recurring since they do not address the
inequalities that perpetuate them. In concurrence with Schulz and Northridge, from whom the
current conceptual model derives, this analysis will focus on a determinant at the intermediate
level in the social context category: industrial codes (see item in red, Figure 1).
Industrial codes related to environmental exposure have been chosen as a significant
determinant because they best meet the main criterion of maximizing the redistribution of health
and power through public health. This is because industrial codes hold accountable industries
and related stakeholders who are usually directly responsible for toxic environmental exposure.
Industrial codes affect and are affected by national and international policies across domains
(such as occupational and environmental health) and nations, and offer opportunities for multiple
stakeholder involvement in the formation, implementation, and revision of industrial practices
outside government bureaucracy. They can interact with policy to institutionalize a set of “best”
practices” to preserve public health. Finally, and most importantly, with respect to this target
population, a code applied to industry is one of only a few tools that can be implemented
transnationally, hold multiple parties accountable, and address local and international factors
affecting toxic environmental exposure.
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QUESTION TWO
The Bhopal Aftermath: the need for accountability
Industrial codes have been recognized as the most important determinant affecting toxic
environmental exposure from the chemical industry. In this regard, the Bhopal Gas Tragedy in
1984 was a watershed event. Insofar as no major policies around exposure to chemical toxins
existed prior to this, Bhopal framed most of the world’s major industrial codes as governments,
UN agencies, and corporations devised strategies to reduce risk and liability while maximizing
accountability and safe operation in chemical industry process management (see summaries of
key interventions, Appendix 2).
In the global arena, the International Program on Chemical Safety, a joint initiative of the
United Nations Environmental Program (UNEP), the International Labor Organization (ILO) and
the World Health Organization (WHO), issued two codes of practice as guidelines for industry
and government (12). These codes, Prevention of Major Industrial Accidents and Safety in the
Use of Chemicals at Work, are nonbinding and have been of little consequence to countries like
the US and India, which did not even ratify the related ILO conventions.
In the US, where most of the world’s largest chemical corporations are headquartered, the
only body creating codes or standards affecting US based industries is the Department of Labor’s
Occupational Safety & Health Administration mandated by the Occupational Safety and Health
Act (OSHA) of 1970. OSHA went into effect in 1970 to enforce industrial standards ensuring
workplace health (40). Even after the poisoning of the West Virginia Union Carbide facility, no
additions or amendments related to exposure or facility management were made to the 1970
standards of permissible chemical exposure levels for workers. As recently as 2002, the OSHA
administration was still enforcing the 1970 standards; its 1991 effort to update standards was
overturned by federal courts (41). The current administration has shelved over a dozen OSHA
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initiatives to update standards (42,43).
Responsible Care®: the chemical industry codifies itself
In the midst of these activities (or lack thereof), the multinational corporate sector crafted
its own industrial code of practices related to toxic environmental exposure. Immediately
pursuant to the Bhopal disaster, in 1985, the Canadian Chemical Producers’ Association (CCPA)
launched its own voluntary code of conduct, Responsible Care®3 (44). Chemical corporations
and associations in 46 additional countries have since followed suit, on US foot-heels (44).
Responsible Care® in the United States
Responsible Care® was adopted in 1988 by the US Chemical Manufacturer’s Association
(CMA, renamed the American Chemistry Council, ACC in 2000). The aims of the program are
to improve chemical processes, significantly reduce waste, minimize accidents, safely produce,
transport, use and dispose of materials, enhance customer relations and service, and increase
communication with the public (45). The Responsible Care® program has amended and adapted
its requirements over the past 17 years; currently, constituent chemical industry firms, as a
condition of their ACC membership, adopt the following:
1. Ten guiding principles that are agreed upon by all ACC member firms (see Appendix 3)
(46);
2. A Responsible Care Management System (which in 2002 replaced the previously upheld
codes of conduct) and related Security Code (see Table 1, below) (47):
3
Interestingly, one of the first companies to endorse Responsible Care® was Dow-Canada (50), whose parent
company acquired the now infamous Union Carbide in 2001 (75). In addition, it is reported that the US chemical
industry adopted Responsible Care® upon the initial suggestion of Union Carbide’s Chief Executive Officer, Robert
D. Kennedy, (50) suggesting important linkages between Dow Corporation, Union Carbide Corporation, and
Responsible Care®.
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TABLE 1: RESPONSIBLE CARE® MANAGEMENT SYSTEM AND SECURITY CODE ELEMENTS (47)
1. Leadership Commitment. Senior leadership commitment to continuous improvement through published policies,
provision of sufficient and qualified resources and established accountability.
2. Analysis of Threats, Vulnerabilities and Consequences. Prioritization and periodic analysis of potential security
threats, vulnerabilities and consequences using accepted methodologies (i.e. those developed by Sandia National
Laboratories, the Center for Chemical Process Safety or equivalent methods).
3. Implementation of Security Measures. Development, implementation, and documentation of site, cyber and
transportation security measures commensurate with risks, taking into account inherently safer process design,
engineering and administrative controls, and prevention and mitigation measures
4. Training, Drills, and Guidance. Training, drills and guidance for employees, contractors, service providers, value
chain partners and others, as appropriate, to enhance awareness and capability.
5. Communications, Dialogue, and Information Exchange. Communications, dialogue and information on
appropriate security issues with stakeholders such as employees, contractors, communities, customers, suppliers,
service providers, and government officials and agencies balanced with safeguards for sensitive information.
6. Response to Security Threats/Incidents. Evaluation, response, reporting, communication and corrective action in
response to threats and/or incidents.
7. Audits and Third-Party Verification. Audits to assess security program implementation and third party
verification at facilities with potential off-site impacts to ensure physical security.
8. Management of Change and Continuous Improvement. Evaluation and management of security issues
associated with changes involving people, processes, products, information or information systems. Continuous
improvement of performance, process planning, establishment of goals and objectives, monitoring, analysis of trends,
and the development and implementation of corrective action.
3. A battery of industry-wide Performance Measures across a broad range of issues
including economics, environment, health, safety, and security (see Appendix 4), to be
made available to the public (This is a recent addition, the reporting requirement for most
of these measures begins this year) (46);
4. Public Dialogue through Community Advisory Panels (CAPs) is required, where
community members, environmentalists, civic, business and education leaders, as well as
health and safety specialists may meet with the management at any facility to discuss issues
of mutual interest (46).
5. Membership in Responsible Care® is open to partner associations and companies
who are not members of the ACC (46). These groups follow the protocol of the ACC as
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members, including payment of fees and accountability to protocol (48) but are not
included in official reporting to the Responsible Care® international governing body (49).
Why the US Responsible Care® Program is a good case study
The most important determinant affecting toxic environmental exposure is industrial
codes governing toxin exposure. Chemical corporations have direct control over exposure and as
such, standards that apply directly to them are most relevant. Responsible Care® is maintained
by and applies to the ACC, which comprises 191 of the biggest chemical firms based in the US,
including large multinational corporations (MNCs) like Dow Chemical, DuPont, and Bayer. In
addition, it is also important to note that this program was developed in direct relationship to the
Bhopal disaster, which is the frame not only of this, but most analyses of toxic exposure and the
chemical industry. Furthermore, unlike OSHA or the ILO conventions, Responsible Care® is
one of the few (if any) interventions that apply to multinational corporations and their
subsidiaries. As the following sections reveal, furthermore, this intervention reveals and affects
the critical health and power inequality dimensions underlying the most important determinant
related to toxic environmental exposure. Given these connections and because of the wideranging implications US industry standards have in today’s globalizing world, the American
Responsible Care® program is an important case-study.
Is Responsible Care® Appropriate?
Appropriateness is considered here in terms of timeliness, relevance to the population of
interest, involvement of key stakeholders in policy development, and consideration of ethical
issues. The adoption of Responsible Care® in the US took place four years after the biggest
industrial disaster in the world. A precursor to the community awareness component of the
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program was implemented as early as 1985 (50), and as such, reflected the urgent desire of the
chemical industry to improve its environmental health and safety standards (and, in tandem, its
public image after the Bhopal catastrophe). Furthermore, as per item five of the code and
component four of the program, the chemical industry is required to have public dialogue
through CAPs which is an opportunity to engage key stakeholders and bridge the health and
power inequalities mentioned in response to Question One. Yet, no mechanism exists to
incorporate the conclusions or findings from public dialogue into the implementation of
Responsible Care®. In addition the caveat “safeguards for sensitive information” may be used as
a loophole for nondisclosure of issues that may be important to the public. The notion of the
chemical industry voluntarily codifying itself at its own pace without penalty has a lot of
practical problems, particularly related to accountability. De facto, the industry is accountable to
itself, which is ethically very weak, particularly from the perspective of those at risk for
poisoning. Indeed, Responsible Care® doesn’t necessarily ensure that a situation like Bhopal
won’t recur (the protracted legal battle around the 1984 gas leak is itself ongoing in spite of this
program, and incidents of toxic chemical exposure have only increased (51). Thus, one must
conclude that Responsible Care® is limited in its appropriateness.
Is Responsible Care® Effective?
Effectiveness is defined as the degree to which a program meets its aims and how well it
improves the health condition of those at risk of toxic environmental exposure. To begin with,
data for international populations could not be found. This could either be because it has not
been made public, or that it is not gathered in the first place. Either scenario reflects poorly on
Responsible Care® and violates its aims of increasing communication with the public. Future
analysis uses domestic data with the assumption that international figures will likely be less
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favorable given the more lax industrial standards in most developing nations. A major issue with
respect to the effectiveness of Responsible Care® is that the frequency and process of
monitoring and evaluation is in large part governed by the ACC. The only penalty for
noncompliance, furthermore, is peer disclosure (i.e. other firms are made aware of your
noncompliance). King and Lenox’s 2000 study concluded that membership in Responsible
Care® was not associated with reductions in toxic release as compared to nonmembers (52),
which violates multiple aims of this program (this will be discussed further in response to
Question Four). Moreover, the US Public Interest Research Group (PIRG) found that 75% of the
facilities were either not willing or unable to share information about chemical risk required by
the Communication, Dialogue and Information Exchange provision of Responsible Care® (51).
This and other examples discussed in response to Question Three suggest that Responsible
Care® lacks effectiveness.
Is Responsible Care® Comprehensive?
Comprehensiveness refers to the breadth, depth, and interrelatedness of program
components. On paper, this program appears to cover many bases, from involving stakeholders
to monitoring and amending security mechanisms. As such, this set of standards has the
potential to affect multiple determinants: it can bring about social justice and corporate
responsibility on the macrosocial/fundamental level, increase civic participation and community
investment at the intermediate level, and reduce stressors at the proximate level. Yet, even on
paper, some of the program components (such as public dialogue) are given tokenistic attention,
raising doubts about the actual comprehensiveness of the program. Moreover, Responsible
Care® allows firms to adopt components of the code at their own pace (53). This is presented as
an incentive inasmuch as gradual adoption reduces the up front costs of membership in the
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program. Yet this feature renders Responsible Care® vulnerable to opportunism and moral
hazard, where firms join the program, and while delaying its implementation, take advantage of
the benefits it affords (mostly reputational). Furthermore, piecemeal adoption of the program
reduces its comprehensiveness for firms and stakeholders. On the industry level as well,
variations in adoption between firms compromises the comprehensiveness of Responsible Care®
overall. The following pages lay out these inconsistencies between firms as well as between the
potential and actual use of the Responsible Care® standards.
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The Walt Policy Framework: actors, context, processes
A useful analytic tool in discussing the financial, implementation and feasibility-related
aspects of Responsible Care® is Walt’s policy framework for international public health, which
focuses on “the role of actors, and how they are affected by, and influence, the context and
processes within which policies are made and implemented”(54). Responsible Care® is not
international policy in its strictest sense. Yet, Walt’s framework applies because the program is
a code guiding processes with transnational implications that have been strongly influenced by
the actors involved in the chemical industry in a specific historical context. In discussing the
financing, implementation and feasibility of Responsible Care®, this analysis will refer to actors,
contexts and processes to demonstrate the relationship between program rhetoric and reality.
Financing
The financing aspects of Responsible Care® have not been made public. Yet, some
conclusions and estimates can be made from internal ACC documentation acquired by the
Chemical Industry Archives on the basis of Freedom of Information Act requests to the
government (48). Responsible Care® activities are funded by annual fees paid by member
companies as a percentage of their annual chemical sales (the calculation rubric is not publicly
available) and flat fees assessed upon partner firms and associations (48). While it is unclear
whether fees assessed upon partner associations and firms are comparable to member fees,
internal documents collected by the Chemical Industry Archives reveal annual partner member
fees of 82,400 USD and higher in 1991 (48).
Some transportation and insurance firms have offered economic benefits and incentives
to chemical companies who adopt Responsible Care® (50), yet small firms in the chemical
industry are reluctant to adopt it. Prakash explains: “Responsible Care® is a project of large
chemical firms that can afford to create specialized structures and employ personnel…in
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contrast, the organizational structures of smaller firms typically reflect little functional
differentiation…there are fewer procedures and relatively less documentation of management
systems” (50). Thus, Responsible Care® is necessarily adopted only by those who can afford it.
The implementation and operational costs of Responsible Care® in each facility are
borne by individual firms. From 1990 to 1996, the ACC (then CMA) spent between 1-2 million
USD per year on implementing Responsible Care® in member companies, and about 8.5 million
USD on advertising as part of a public outreach campaign to improve the public image of the
chemical industry (48). The 1984 Bhopal Gas Tragedy and the 1989 Exxon Valdez spill provide
context to this skewed allocation of resources: the chemical industry had a very poor reputation
at this point. Their process: greater fiscal emphasis on ameliorating the chemical industry’s
public image (a 4% increase was seen in favorable public opinion in 1995 (50)) than on
improving its safety procedure and operations. From the perspective of the chemical industry,
this is cost-effective; this opinion is not shared by other actors and stakeholders (labor unions,
community members, and environmental experts) (48,51,55). Unfortunately, these groups are
often excluded from the implementation process and only involved at the outcome level (when
exposures occur).
Implementation
At the outset, the structure of the US chemical industry explains the origins and current
implementation of Responsible Care®. The industry is oligopolistic, with a small number of
very large firms dominating the industry’s practice (56). These large firms internalize a large
portion of the collective reputation of the industry (57), and in response, initiate the
establishment of industry standards and codes. This is especially true in the environmental
health arena (58). The voluntary and self-regulatory nature of Responsible Care® allows the
hegemons within these oligopolies to pursue their self-interest on their own terms (50), and
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create benefits for others in the process.
These factors explain the chemical industry’s deliberate central role as an actor, which in
turn creates a context of diffusion and staggered implementation of Responsible Care®. To
begin with, Responsible Care® charges chemical companies themselves to plan, implement, and
update its components. The only time when companies may not completely drive the process is
in the monitoring phase of implementation, that too, at firms’ own discretion. One such
opportunity arises in the form of Citizen Advisory Panels that generate feedback on public
perceptions and concerns. While there is evidence for CAPs changing facility practices (59-61),
studies also suggest that CAP participants tend to be very similar to facility managers in most
sites and rarely comprise environmental advocates (62). Since the selection of CAP members is
the prerogative of firms themselves, it appears that many firms are deliberately losing the
richness and relevance of feedback and information that could be obtained from a broader
selection of CAP members. More likely than not, stakeholders (such as at-risk populations) with
opinions that are unpopular with facility managers are purposely not represented in CAPs and
consequently play no role in the implementation of Responsible Care®.
Additionally, firms have the discretion to choose peer auditors to verify whether or not
management systems are in place (63). Stronger, more public and participatory monitoring
mechanisms exist, such as those conducted by the public or third parties (this latter option is
required for the ISO 14001, another industrial environmental health and safety code) (11). Yet,
the ACC has deliberately chosen not to administer these methods of verification for Responsible
Care®, losing the value addition of external expertise and approval. Another weakness is that
while auditors verify the presence of a management system, firms conduct system performance
evaluations themselves (it must be noted that performance evaluation standards were only added
in 2002; the first round of reporting for most measures began last year, see Appendix 4).
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Evaluating performance is a key area where the involvement of stakeholders could improve
health outcomes. Responsible Care® does not enable this. Another weakness of implementation
is that the highest sanction for incomplete adoption of Responsible Care® is peer disclosure.
This is a weak sanction; a stronger sanction would be public disclosure of company compliance
to safety standards, which would allow the public to place pressure upon and thus increase
stakeholder involvement with Responsible Care®.
Nash describes the placement of Responsible Care® in a diffusion model of strong and
weak sanctions and monitoring (see Appendix 5). Responsible Care® is located at the center of
the matrix, which is characterized by an accountability vacuum (63). It is no surprise, then, that
practices across US firms are inconsistent. A 1995 study found substantial variations –a diffusion
–in the adoption of Responsible Care®, as per the following typology in Table 2:
TABLE 2. HOWARD AND COLLEAGUES’ LEVELS OF RESPONSIBLE CARE® IMPLEMENTATION (62)
1. Drifters were companies that said Responsible Care® had little impact on their activities. Changes were
limited to documenting existing practices.
2. Promoters used Responsible Care® mainly to promote a strong environmental reputation to external
stakeholders, and Responsible Care as “formalizing” and “standardizing” what they already did.
3. Adopters saw Responsible Care® as a valuable tool for improving their environmental practices and had
introduced new practices in community relations and distribution
4. Leaders spoke about Responsible Care being a “whole new way of thinking;” that whereas their environment,
health, and safety (EHS) practices were strong before Responsible Care, the initiative offered a way to
progress
The above trend in the adoption of Responsible Care® reflects the Rogers’ model of
Diffusion of Innovations (64) that the EPA reports is typical in environmental health
management (65). Inasmuch as Responsible Care® is self-regulated, however, it is unclear
whether the firms in each category will remain in their positions, or if pressure from the latter
categories will cause a shift to more concerted implementation of the program, as theorists
suggest (66). Finding and predicting trends is difficult since variability exists both within and
between firms. Nash concludes: “firms adopt Responsible Care® in their own way, at their own
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pace, and results in terms of environmental performance vary substantially” (63).
Feasibility
The implementation of Responsible Care® across the industry is inconsistent and its
effectiveness in meeting public health targets, questionable (this is discussed in responses to
Question Two and Four). Yet for the ACC, Responsible Care® is cost-effective, sustainable, and
feasible: it has lasted over 17 years. Questions of feasibility arise when other stakeholders, the
global context, and alternatives to Responsible Care® are considered.
The international coordinating body for Responsible Care®, the International Council of
Chemical Associations (ICCA) admits in its 2002 report that it has been “slow to recognize the
need for, and implementation of, effective partnerships with critics” (49). Potential critics have
been excluded from the CAP process in the US (62) and inasmuch as many of these critics
reflect the concerns of stakeholders most vulnerable to toxic chemical exposure, the chemical
industry is making itself vulnerable to great criticism should another event like Bhopal recur.
The ACC scaled up its engagement with state and federal government stakeholders and created a
Security Code in 2002 in the midst of rising political concerns over the risk of chemical exposure
from terrorist attacks after 9/11, (47). Yet, taking a closer look at the Security Code, one sees
almost complete overlap with the previous Responsible Care® management system (so much so
that they are presented together in this analysis). Unfortunately, from Bhopal to 9/11, it appears
that the main motivation for ACC to involve more stakeholders or amend Responsible Care® is
when a disaster has occurred or when the threat of one is highly politicized.
On the global scale, meanwhile, the ACC has jeopardized broader implementation and
endorsement of Responsible Care®. In 2001, efforts to reach a global agreement on Responsible
Care® with the International Federation of Chemical, Energy, Mine and General Workers’
Unions (ICEM) were thwarted by the ACC, apparently at the behest of ACC members Exxon
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and DuPont (55). A global agreement would have set the stage for international cooperation,
monitoring, and endorsement by a wider spectrum of stakeholders (beyond ICEM). More
importantly, setting uniform international standards for occupational and environmental health
and safety would directly address the inequalities and inadequacies that caused the Bhopal Gas
Tragedy in the first place. The ACC’s actions have soured its relations with other national
chemical associations and may have long-term effects on the American chemical industry and
Responsible Care®.
Interestingly, there are few if any major differences between the Responsible Care®
guidelines and alternatives (for a list, see Appendix 2). This is because in most cases,
Responsible Care® incorporates these standards in its own framework (48). This strategy allows
Responsible Care® be at par with existing standards, but enforce them more loosely. Yet, in the
long run, this may cost Responsible Care® its popularity in the chemical industry, particularly as
non self-regulated codes become more commonplace worldwide.
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Evaluations of Responsible Care®
No official or ACC-endorsed evaluations of the Responsible Care® program exist.
Instead, the ACC has posted some statistics on environmental health standards on the US
Responsible Care® website (www.responsiblecare-usa.com), based on member company
reports. A useful theoretical assessment of the program was carried out by Prakash using various
economic theories to discuss Responsible Care’s® voluntary nature (50). The National Public
Interest Research Group, a nonprofit watchdog, conducted original research and published two
reports: one in 1998 based on interviews of facility staff from ACC member firms and the second
in 2004 based on chemical incident reports to the National Response Center (51,67). While the
latter of these is the most recent evaluation of Responsible Care® and shows interesting trends
across time, location and by company, the relationship between these elements and other
variables is not explored. It is a descriptive study and lacks the richness that befits a more
thorough evaluation of Responsible Care®. Nash teamed with Ehrenfeld to compare
Responsible Care to other industrial codes in the United States (42) and with Lenox to compare
codes across industries (68). However, given the previous discussion on the implementation and
feasibility of Responsible care, the most appropriate evaluation is King and Lenox’s 2000 study
looking at predictors of membership as well as a case control comparison of environmental
performance (52).
The King and Lenox evaluation: purpose, process and design
As mentioned earlier, the aims of Responsible Care® are to improve chemical processes,
significantly reduce waste, minimize accidents, safely produce, transport, use and dispose of
materials, enhance customer relations and service, and increase communication with the public
(45). King and Lenox’s 2000 study evaluates the first four of these aims. Its purpose was to
determine whether industrial self-regulation within for-profit industries can be effective, looking
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specifically at the characteristics of Responsible Care® formation and membership, as well as
members’ environmental performance and improvement of relative to nonmembers in the
industry (52). These researchers’ work was supported by the Massachusetts Institute of
Technology (MIT) Business and Environment Program and carried out by researchers on MIT
and New York University premises. Data was collected from the Environmental Protection
Agency’s (EPA) Toxics Release Inventory (TRI)4 which has collected facility-level reports of
the emissions of over 200 toxic chemicals from US manufacturing firms from 1987 onwards.
While the researchers do not indicate their sampling strategy, it appears that all observations
within the chemical industry in this inventory were used, comprising 22,476 observations from
3,606 facilities and 12,829 observations from 3,606 firms in the period 1987 -96. Of this group,
Responsible Care® membership was determined for all firms in the period 1990-6, and CMA
membership in the three years prior (1990 was chosen as base year because Responsible Care®
was ratified by the industry in October 1989). Researchers found that Responsible Care® firms,
due to their size, accounted for as high as one-third of the facilities reported in the TRI in a given
year.
Table 3 below outlines the variables used in this study, and their measurement.
TABLE 3. VARIABLES AND MEASUREMENT IN KING AND LENOX (2000)
VARIABLE
MEASUREMENT
CMA Membership/
Using data from the CMA firms and facilities were binary coded (yes/no) for each year (1987Responsible Care®
96)
Participation
Environmental
(Weighted) emissions were calculated using yearly averages of pounds of emission for
Performance,
facilities with weights for production in each facility as a proportion of its parent firm’s
Relative and Sector
productivity, and emission toxicity (as per EPA standards).
Relative Emissions at the facility level were calculated (using ordinary least squares regression)
as the deviation between observed and predicted emissions given facility size and sector.
Sector Emissions at the firm level were calculated in groups based upon Standard Industrial
Classification (SIC) codes, which codify sectors by the level of hazardous emissions.
4
The TRI was created in 1986 in direct response to the Bhopal Gas Tragedy as part of the Emergency Planning
Community-Right-to-Know Act (see response to Question One). As per this Act, businesses are required to report
chemicals release to the TRI for each facility on an annual basis (10).
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VARIABLE
Environmental
Improvement,
Absolute and
Relative
Organization Size
Focus within the
chemical industry
Firm visibility
MEASUREMENT
(Researchers refer to these in their analysis as more or less dirty firms.)
Absolute improvement was measured as the percent change in total weighted emissions over
one year
Relative improvement measured the percent change in relative emissions (see above) over one
year
Size was measured as a log of the sum of all employees at all of the firms facilities using Dun
& Bradstreet
Focus was measured as the log of the total number of employees in the chemical industry over
the log of the number of employees in the company (this variable grew with the degree to
which a company was focused on chemicals)
Visibility was measured as a continuous variable varying from 0 to 1 based on a random sample
survey of students (n=25-35) at the NYU Stern School of Business. Visibility was determined
as the percentage of students who recognized a company’s name and/or brand out of the
number who were asked to respond for that company.
King and Lenox used these eight measures to test five hypotheses related to Responsible
Care® membership, environmental performance and improvement. The researchers’ hypotheses
analytical strategy, and findings are presented in Table 4 below:
TABLE 4. HYPOTHESES, ANALYTICAL STRATEGY, AND FINDINGS FROM KING AND LENOX (2000)
HYPOTHESIS
ANALYTICAL STRATEGY
SIGNIFICANT FINDINGS
(P<0.001)
1: Firms are more likely to A probit model was used; the likelihood
Larger firms, those firms whose business
be members of the CMA
that a given firm within the chemical
was focused in chemicals, and more visible
and participate in
industry will be a CMA/Responsible
companies were more likely to be
Responsible Care® if they Care® member was the dependent
CMA/Responsible Care® members. In
are larger, more focused in variable; independent variables were
1990, the likelihoods of membership were
chemicals and have high
relative emissions, focus, visibility, and
24%, 47% and 124% higher for these
visibility
size. Three models were devised for (a)
groups, respectively. Of particular interest is
the membership in 1990, (b) entrants in
the strong “visibility” effect.
1991-6, and (c) exiters in 1991-6
There were no significant differences
between firms who joined Responsible
Care® and firms who left it from 1990-96
2: Firms are more likely to The probit model above was used
Companies with weaker environmental
be members of the CMA
performance relative to their sectors (the
and participate in
relative emissions variable) and higher
Responsible Care® when
sector emissions (i.e. companies that are
they have higher levels of
dirtier) were more likely to be
pollution relative to their
CMA/Responsible Care® members. In
industries, operate in
1990, higher relative emissions firms were
industry sectors with
24% more likely and higher sector emissions
higher average levels of
firms were 45% more likely to be members
pollution
3: On average, firms that
A generalized least squares regression
Models explain only 5-7% of the variance.
participate in Responsible model was used with White’s correction
Data provide no evidence that the rate of
Care® will improve their
for heteroskadasticity (increasing
environmental improvement is higher in
environmental
variance with size of variable) and a
members. In fact, members were found to
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HYPOTHESIS
performance more than
nonmembers in the
industry
4: On average, the
chemical industry will
more rapidly improve
environmental
performance after the
inception of Responsible
Care®
5: In direct contrast to
Hypothesis 3, on average,
participants in Responsible
Care® will improve their
environmental
performance less than
nonmembers in the
industry
ANALYTICAL STRATEGY
fixed-effects specification (where, in
longitudinal data sets, unobserved
heterogeneity can result in incorrect
inferences about the significance of
individual effects) and robust
specification to control for nonnormal
data. Absolute and relative environmental
improvement were the dependent
variables; the independent variables were
membership, relative emissions, sector
emissions, focus, visibility, and size.
Estimates were calculated at the firm and
facility level
A similar generalized least squares
regression model was used with an
interaction term for two time dummy
variables, the 1987-89 period and 199096 period. Absolute rates of
improvement were the dependent
variable; the independent variables were
membership, time, sector emissions,
focus, visibility, and size
The model for hypothesis 3 was used
SIGNIFICANT FINDINGS
(P<0.001)
be improving up to 5% slower in
comparison to nonmembers (although this
may attributable to low turnover in
Responsible Care® membership)
Models explain only 2-3% of the variance.
The rate of improvement in the entire
chemical industry increased around 12 %
firm wide and 19% at the facility level after
the inception of Responsible Care®.
However, the rates of improvement in
member firms and facilities were lower (9%)
overall and did not significantly chance after
1990. Researchers suggest this may have
been because nonmembers, because of their
non-adoption of Responsible Care®, were
under increased pressure and scrutiny and
improved environmental performance more
rapidly
Models explain only 5-7% of the variance.
In tandem with Responsible Care®
members’ slower relative environmental
performance compared to nonmembers, their
absolute environmental performance is
lower, though not significantly.
In summary, this evaluation of Responsible Care® found that members typically
comprise large, highly polluting, and highly visible firms who have improved environmental
performance slower (and less) than their nonmember peers through 1996.
Strengths and Weaknesses in Design, Measurement, and Conclusions
King and Lenox’s study design has high face validity because it contextualizes
Responsible Care’s® relationship to chemical exposure by looking at factors related to
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membership, firm design and focus. The use of the EPA TRI database shows good criterion
validity because it looks at exposure and emissions data and is discriminant from accident data
used in other evaluations (51). (Chemical exposure can have long ranging effects that are often
not recognized or reported as accidents.) The established EPA measure of toxicity was preferred
by researchers over the newer, less validated scale developed at Purdue, showing attention to
validity and reliability issues. This evaluation has good explanatory power as a result.
The researchers show innovation and expertise in measurement design, using weighted
scales for emissions, gathering data across firms and facilities, undertaking a mini-survey project
to determine the variable for visibility, and applying a case-control analysis on longitudinal data.
The strength of design is that all emissions data are used (randomization is not necessary!) and
while the research is unobtrusive and observational, a pre-test post-test control group design is
used (observations comparing member and nonmember firms from before and after the
ratification/widespread adoption of Responsible Care®). Most threats to internal and external
validity such as selection, instrumentation, attrition, and the interaction of treatment with
selection are thus bypassed.
Notwithstanding, King and Lenox’s study has some limitations. Researchers admit that
they were unable to completely control for differences between facilities, which may vary greatly
within and across companies based on factors not included in the model, such as type, age and
location of facility. Another major limitation is the possibility that the greater number of
emissions observed for Responsible Care® members is actually a result of more diligent
reporting as required by the code itself. Researchers devised the improvement variable to capture
such differences, yet if reporting became more stringent as time went by, this is likely to offset
improvements in environmental performance for member companies. This is an external validity
threat where testing and treatment interact. Finally, King and Lenox point out that the industry
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reduced emissions by nearly 50% in this period, which may or may not be attributable to
Responsible Care®. Indeed, at this time, the government sponsored 33/50 industrial code was in
place, requiring firms to reduce emissions by 50% by the year 1995(11): this is a clear case of
multiple treatment effect.
Beyond what the researchers report, an important limitation of the study is its outdatedness (data from 1987-96). Responsible Care® has undergone some significant changes from
2000 onwards, such as the changing of CMA’s name to the ACC, a performance reporting
requirement and third-party systems verification option, which are specifically crafted to
improve management for better environmental performance and increase public approval. The
changing nature of the treatment creates an external validity threat and limits study
generalizability. Furthermore, the models used for Hypotheses 3-5 in this study have very low
regression coefficients, suggesting that many other factors not addressed here (such as location,
state and federal policies- the 33/50 program- and perhaps CAP involvement) affect
environmental performance. In addition, the frame of yearly improvement in environmental
emissions may not reflect program effect inasmuch as codes and standards may take longer to
affect environmental performance. An absolute change measure across the five-year period may
reveal such trends. Differences between firms could also be analyzed more specifically by
collecting quantitative data using Howard and colleagues typology (see Table 2, (62)).
This evaluation of the Responsible Care® is very telling and despite limitations,
important conclusions can be drawn from it, not the least of which is the following:
The chemical industry affects a physical commons – clean water, clean air, and health ecosystems
– but it was not the threat that this shared public good that motivated the industry’s initial attempts
at self-organization. Rather it was a threat to a second, reputational commons that sparked the
creation of Responsible Care (52).
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The reputational commons motivation behind this self-regulated industrial code has wideranging implications for future research, intervention design, and policy development around
toxic environmental exposure. The following section explores future directions in these areas.
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Responsible Care®: whose health?
The most important determinant with respect to toxic chemical exposure from industry is
industrial codes of conduct. Inasmuch as Responsible Care® is the oldest and largest industrial
code in the chemical industry (see Appendix 2) it is at the center of this analysis. However, as
this analysis has shown, Responsible Care® has thus far failed to meet its own aims and had
little impact on improving environmental health outcomes and reducing risk. It has, however,
succeeded in improving the public image of the chemical industry after a series of accidents in
the 1980s (11,48,50,52). So, whose health does Responsible Care® protect and why?
It seems as though most of the provisions of this code ensure the economic and social
health of companies rather than the health of communities at risk of toxic exposure from their
activities. King and Lenox describe this ethos of having the “reputational commons” (see quote
in response to Question Four) be the operative goal driving the formation of Responsible Care, at
the expense of the ACC’s publicly touted “physical commons” goal (52). In the era of
globalization, where market profit is the bottom line, it is perhaps naïve to think that an industrial
self-regulating code would operate differently from how Responsible Care® has. This combined
with the US ethic of individualism explains the way in which the ACC has operated. Given this
ethic and a market profit motive, the ACC, holding its own interests above all others, has chosen
to self-regulate in order to maximize control over its processes and deflect regulation. Inasmuch
as those affected by and at risk for toxic chemical exposure are poorly represented in the ACC,
they neither control the code nor the operative goals that guide it.
The unfortunate consequence is that Responsible Care® maintains the health and power
inequalities industrial codes otherwise have the potential to reduce (described in response to
Question One). Thus, the issue here is not that industrial codes are a poor determinant of
environmental health but rather that certain qualities of Responsible Care® (its voluntary nature,
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lack of sanctions and rigorous monitoring, and premise of self-regulation) render it an inefficient
strategy in addressing this determinant. This analysis explores other aspects of Responsible
Care® that might make it more capable of addressing the problem, such as research, additional
components/ interventions, and/or policy. Furthermore, there are research, intervention and
policy strategies outside the scope of Responsible Care® that may prove also useful in
addressing the public health problem. The most appropriate of these is discussed in conclusion.
Making Responsible Care® more responsible: research, intervention and policy directions
As explained in response to Question Two, surveys of Responsible Care® member firms
show a diffusion of adoption (62). Studying the proportions and characteristics of this diffusion
may help the ACC devise strategies to increase and equalize membership and compliance. The
biggest gap in research, however, is regarding the adoption and implementation of Responsible
Care® internationally. While Responsible Care® standards apply for all facilities, no data from
outside the United States is reported on the Responsible Care® website. Some firms such as
Dow and Bayer indicate that they follow Responsible Care® standards (69,70), but data on their
environmental performance is not available for all countries. Researchers outside the industry in
the fields of environmental and occupational health, industrial management and policy, and
international development and globalization studies have not looked at this either. As firms
increasingly outsource production and manufacturing to the developing world, this research
trajectory will be very important in monitoring the environmental effects of Responsible Care®.
The issue of monitoring is a contentious one with respect to Responsible Care®. In the
US, third parties from the industry are involved on a discretionary basis in monitoring American
companies. In Canada, Responsible Care® is verified by four-person teams which are wholly
independent of the company, composed of ordinary citizens, industry members,
environmentalists and academics (11). Over several days, each team goes on plant tours,
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conducts extensive interviews, examines company documents and makes calls to neighbors,
customers and suppliers. Team members then write a detailed report, and the company shares
the results of that report with employees, neighbors and peers. It seems that in Canada, the
reputational commons and physical commons are perceived as being far closer together, such
that the industry is willing to divest some regulatory power to third parties potentially affected by
its activities to improve its public image. This logic and monitoring method may be worth pilot
testing in the United States as a small-scale intervention, though strong industry resistance to this
idea would have to first be overcome.
Another intervention that could be tested with relation to Responsible Care® is the use of
harsher sanctions. Currently, noncompliance in the adoption of Responsible Care® components
is sanctioned by peer disclosure. Public disclosure (which has worked well in Canada (11)) or
some kind of mandatory fine mutually agreed upon by the ACC may raise accountability and
compliance in the industry. Here, one could rely on the lobbying efforts of subsidiaries of large
multinationals that operate in countries with more stringent Responsible Care® regimes. For
instance Dow-Canada could encourage or incentivize its US partner to advocate public
disclosure or fines in the US setting. Given the size and influence of this corporation, it is likely
that if Dow-US pushes for sanctions, the ACC will be able to get more companies on board.
On the policy level, Responsible Care® could really benefit from more stringent
government control over the industry. As mentioned earlier, the post 9/11 emphasis on chemical
security in case of terrorist attack has resulted in the adoption of the security code element in
Responsible Care®. Yet this code comprises no new elements. This undermines the heavy
reliance of chemical security on a company’s environmental and health standards and the need
for more stringent controls, especially in the event of a terrorist attack. Strategically, federal and
state governments could use the frame of chemical security to legislate more stringent oversight
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of Responsible Care®. This would reduce the regulatory power the chemical industry now
exclusively holds, make it more accountable for and attentive to potential sources of
environmental and occupational ill health.
Furthermore, the 2001 impasse with respect to a global agreement on Responsible Care®
(discussed in response to Question Three) should be overcome. Here, the global Responsible
Care® leadership should apply pressure on the ACC to compromise with the international union
association ICEM and agree upon a draft international resolution. The new sense of urgency
around toxic exposure and chemical security post 9/11 should be leveraged as an impetus to
bring all stakeholders back to the table.
Responsible research, interventions and policy outside Responsible Care®
Alternative industrial codes have been unpopular in the US (71)even though there is a
significant degree of overlap between them and Responsible Care® (13,42). While selfregulation may be the tipping point in companies endorsement of industrial codes, more
comparative research is needed to determine which codes produce the best health outcomes
internationally and how they can be made more popular and relevant in the US context. This,
again, is an attempt to bridge the divide between reputational and physical commons discussed
earlier. Moreover, additional research involving multiple stakeholders in the chemical industry
(such as vendors, policymakers, community members, and environmental experts) could reveal
pathways to bridging this divide. Research could focus not only on stakeholder perspectives on
industrial codes, but their ideas on how to realistically improve them. Once published, this
research may be used to leverage public opinion and motivate the chemical industry to improve
its practices.
The involvement of worker unions in the Responsible Care® process has taken place in
other countries (mostly European) (49) but not in the US. While there is a strong degree of
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antagonism between the chemical industry and the union movement, unions have been able to
leverage regulations around occupational health and safety, particularly at the state level (72,73).
US unions could perhaps devise or adapt an industrial workers code based on their interests
based on the premise of occupational health and consultations with their international
counterparts to lobby the government for support. Thus, a code created as an intervention could
become institutionalized as policy on the state level, and eventually affect industry on the federal
level. While this involves expending large amounts of resources, in the long term, it may prove
cost effective for unions, especially considering the number of occupational accidents that
continue to occur in the chemical industry (15,51).
Bridging the “Physical-Reputational” Commons: Purposeful Research as the best next step
Public opinion has been a driving force behind reform in the chemical industry; research
can play an important role in shaping public opinion. As mentioned earlier, a significant gap in
international research is around the Responsible Care® programs of US-based industries in the
developing world. The next best step is to take advantage of these three facts. Schools of Public
Health and Business in credible institutions such as Johns Hopkins and MIT should divert their
research dollars towards looking at incidences of exposure, health outcomes, and management
practices associated with Responsible Care® multinational facilities all over the world. The
emphasis should be on developing strong research methodologies to make well-substantiated
conclusions about an environmental health “story” that the media can pitch to the public. Thus,
research can feed the media, driving drive public opinion which could apply pressure on the
ACC to improve the practices of Responsible Care® across the board. In this way, researchers
are uniquely positioned to initiate the bridging of physical and reputational commons to improve
industrial standards and codes across the world and reduce the global risk of toxic environmental
exposure. Indeed, the legacy of Bhopal demands it.
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