Our approach to plant, process and transport safety
Preventing harm to human health and the environment is one of our top priorities. We have management systems in place to help ensure the safety of our plants and processes and to protect our employees and the environment. In addition, we do everything in our power to ensure that our chemical and pharmaceutical compounds are transported and stored properly.
We seek to minimize manufacturing process hazards wherever possible in order to prevent workplace accidents, production outages and chemical spills, which is why we regularly review our approach to plant and process safety and continuously gauge it using our EHS performance indicators.
Moreover, all our shipments are to reach our customers and sites safely, undamaged and with the required safety information. Several of the materials we store and transport are classified as hazardous. The storage of such dangerous goods and the transport thereof – whether by road, rail, air, or water – are governed by global regulations. To minimize risks to people and the environment, we apply strict safety requirements across the Group that also comply with applicable laws. We conduct regular reviews to ensure our own warehouses as well as those of third parties comply with these regulations. In 2022, no third-party audits were conducted due to Covid-19.
We train our employees regularly in an effort to prevent human error and also to detect technical defects before they can cause harm.
Roles and responsibilities
Overriding responsibility for plant, process and transport safety lies with the Group function Corporate Sustainability, Quality and Trade Compliance (SQ), which coordinates plant and process safety for the company and defines Group-wide EHS standards and regulations. In addition, our individual sites are subject to national and international regulations governing environmental stewardship and public safety. At the local level, the respective site directors are responsible for ensuring compliance with all safety requirements.
If required, we have appointed an EHS manager for our sites as well as a dangerous goods manager for sites with logistics activities with relevant amounts of hazardous materials.This role corresponds to the EU regulations pertaining to the “Dangerous Goods Safety Advisor”. Both individuals advise the site manager on plant, process and transport safety and regularly monitor compliance with safety requirements.
Our commitment: Internal standards and international rules
To ensure safe operation throughout the lifetime of a plant, our Group-wide EHS standards contain specific rules for production plants and processes. These include specifications that determine how special risk analyses and hazard assessments are to be carried out. We have also defined measures for the event of accidental release of chemical substances and for fire protection.
Our Group-wide EHS standards stipulate the safety levels for the storage of hazardous materials at our sites. Along with supplementary standard operating procedures and best practice documents, these EHS standards describe the technology, equipment and organizational infrastructure needed to achieve the appropriate safety levels. Contract warehouses must also adhere to our strict safety requirements. Before we sign a contract with an operator, they must submit a statement detailing how they meet our prerequisites. Our Group-wide EHS standards also define the technical and organizational requirements for such warehouses.
Our Group Transport Safety Standard is based on the United Nations Recommendations on the Transport of Dangerous Goods. This guideline is especially important for sites in countries with inadequate local regulations covering the conveyance of hazardous materials.
Assessing potential risks
Before commissioning a plant, we draft a safety concept, which is subject to continuous review throughout the entire lifetime of the facility. It is updated as needed until the facility is decommissioned. This safety concept contains an overview of potential risks and specifies corresponding protective measures. In the event that alterations are made to a plant, we reassess the hazard and risk situation. Our Risk Management Process guides all our sites in identifying and assessing risks and serves to devise further measures to minimize them.
We use internal EHS audits to complement the inspections conducted by our EHS and dangerous goods managers in order to ensure that our sites comply with process, plant, transport, and storage safety regulations. Normally, these audits are conducted every three years at production sites and every four years at warehouse and distribution sites. If major shortcomings are identified, we re-audit the respective site the following year. Conversely, we may decide to extend the period between audits at facilities where, based on the findings from previous audits, we deem the potential risk to be low. Our sites are required to rectify any deficiencies discovered during the audit, with the auditor subsequently checking whether the specified corrective actions have been taken. In 2022, we conducted 41 EHS audits in accordance with our Group-wide EHS standards.
We report transportation incidents and accidents in accordance with the recommendations on the Transport of Dangerous Goods – Model Regulations (UN Orange Book, 7.1.9) in conjunction with the criteria of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR, 1.8.5.). There was no reportable event in the reporting period.
Keeping a close eye on safety
We track EHS performance indicators at all production and warehouse facilities, as well as at major research sites, including both accidents and near misses. We investigate each individual incident and then devise appropriate countermeasures in an effort to reduce the likelihood of such events reoccurring in the future. EHS performance indicator data are reported once a month within each business sector, with the Executive Board receiving reports on the topic once per year. Four indicators are particularly important to us:
- Under our EHS Incident Rate (EHS IR), we track and evaluate all major and minor accidents and incidents as well as further EHS-relevant incidents. The EHS IR covers both our own employees as well as those of contractors. To calculate it, we state the number of incidents and the severity of the event in relation to the number of hours worked. The lower the EHS Incident Rate, the safer the site is. In 2022, the ratio was 2.8 (2021: 3.9). The significantly lower rate is attributable to the fact that we have now fully included all office sites in the assessment.
- The EHS IR also includes our Loss of Primary Containment (LoPC) indicator. In 2022, we recorded two significant incident-related spills. One took place at a production site in Germany, the other one at a site in the United States. In neither case were people injured nor were negative environmental impacts expected, which is why it was not necessary to communicate these incidents to the public.
- The EHS Leading Rate (EHS LR) reflects the number and the results of the analyses of near misses and critical situations.
- For the Lost Time Injury Rate (LTIR) we set ourselves the goal of bringing our Group-wide LTIR below 1.0 by 2025 (number of accidents Group-wide resulting in at least one missed day of work per million hours worked). In 2022, our LTIR of 1.2 remained unchanged in comparison with the previous year.
In January 2022, we harmonized our approach to audits and reporting by introducing standardized third-party warehouse audits by EHS managers. This approach will help us to more effectively identify areas for improvement at third-party warehouses and our interfaces, and better compare the third-party warehouses with each other and with our own warehouses.
Employee training and best-practice sharing
In line with their specific tasks and responsibilities, our employees undergo regular training that is conducted by either their respective supervisor or our EHS managers. They present Group-wide EHS standards as well as site-specific standards and processes, address changes to international requirements and explain the proper procedures for dealing with incidents. In addition, all newly hired EHS managers complete introductory courses on plant and process safety during their EHStart-up! onboarding.
In the interest of improving safety, we consider it extremely important to continuously share best practices and lessons learned. Once a month, for instance, site directors and EHS managers participate in safety leadership calls to learn from incidents at other facilities and implement preventive measures. Additionally, the EHS managers of the individual sites regularly hold lessons-learned sessions.