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European Association of Chemical Distributors Business Plan 2015 November 2014 www.fecc.org

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  • European Association of Chemical Distributors

    Business Plan 2015

    November 2014

    www.fecc.org

  • Table of Contents

    Foreword ................................................................................................................. 3

    Executive Summary ................................................................................................. 4

    Fecc 2014 survey (Data 2013) ................................................................................... 8

    International Trade Committee ...............................................................................12

    SHE Committee .......................................................................................................13

    Responsible Care Committee ..................................................................................15

    Product Stewardship Committee .............................................................................18

    GTDP Committee .....................................................................................................19

    Precursors Committee ............................................................................................20

    Logistics Committee ................................................................................................22

    ESAD Steering Committee .......................................................................................23

    Fecc Secretariat

    Uta Jensen -Korte Director GeneralSarah Anhorn Office ManagerJoel DSilva Life Science & International Trade ManagerAlexandra Mengesha Communications and Membership Development Manager

    Ophlie Roblot Health, Safety & Environment ManagerJan Thienpont Responsible Care & Logistics Manager

    2 | Fecc Business Plan 2015

  • Foreword

    Dr. Uta Jensen-Korte

    Director General

    The Chemical distribution industry is a vibrant and professional industry which has demon-strated its strength by overcoming challenges and emerging intact despite the economic context of recent years . Wi thout a doubt, the industry plays a key role in the supply chain and truly adds value to the manufacturers which distributors work closely with and to the customers they serve. In response to these realities the chemical distri-bution industry has to continue seeking ways to add further value and to answer customer demands. It is a fact that there is an ever increasing legislative burden impacting the industry. Whilst we welcome the initiatives of the European Commission to improve the regu-latory landscape, it is also vital that distributors are fit for purpose, ensuring they meet all legal and environmental requirements.

    The Business Plan 2015 is a statement of commitment to continue to support our members with high quality services through our expert committees. It is intended to help our many stakeholders understand the global marketplace and the regulatory framework surrounding it. The report also gives an update

    of the recent significant work efforts and accomplishments made by Fecc, in particular that of the expert working committees.

    A revised strategy wil l be presented for approval at the Extraordinary General Assembly Meeting at the Membership Meeting in November.

    On a positive note, the past year has seen our association gain two additional members; CGChemikalien and 2M Holdings; both of them are true success stories in the chemical distribu-tion industry. Membership development remains a priority to strengthen our position as the Euro-pean Voice of the Chemical distribution industry.

    In 2015, Fecc will continue working to ensure the chemical distribution industry is sustainable, and that our members remain fit to tackle the chal-lenges of the future.

    Wishing you a pleasant reading,

    Moving ahead Building a Sustainable Future

    Dr. Uta Jensen-Korte, Director General

    Fecc Business Plan 2015 | 3

  • Fecc in a NutshellOur Mission

    Promote the chemical distribution industry in order to ensure a sustainable business environ-ment for the sector in the short, medium and long term. Fecc represent members interests at the European and international level, while fostering cooperation within the chemical distri-bution sector.

    Objectives

    ,, Monitor regulatory affairs and represent the industrys views before the European Institutions.,, Increase sustainability by promoting the implementation of the Responsible Care Programme.,, Serve as a platform to reach out to internal and external stakeholders.,, Provide expertise and advice to the members. ,, Strengthen relations between the chemical distribution industry.

    Vision

    Become THE opinion maker within our Industry so that we are the natural partner for our members, European Institutions and stakeholders.

    Membership Benefits

    Representation : Fecc actively participates in the European policy development. Representing the industrys interests and views before the European Institutions, through commenting and contributing in consultations relevant to our members.

    Working Committees : Expert committees work on diverse topics important for the chemical distribu-tion industry. The committees develop advocacy positions and provide the members with regular updates and advice on key industry information, market developments and relevant legislation.

    Key Information : Feccs members receive key information via newsletters and subject

    Executive Summary

    Advocacy

    Expertise

    Communications

    Networking

    We areTHE voice

    of ourindustry

    4 | Fecc Business Plan 2015

    Fecc Board

    Fecc President : Neville Prior CBA (UK Association)Fecc Vice-President : Francois-Xavier du Passage UFCC (French Association) Fecc Treasurer : Peter Skou R2 Group A/SFecc Honorary President : Edgar E. Nordmann (NRC)

    Giorgio Bonetti AssICC (Italian Association)Ann-Christin Ericsson IKEM (Swedish Association)Thorsten Harke VCH (German Association)Gordon Hay Brenntag

    David Jukes UnivarEduardo Parella QuimidrogaFrank Schneider IMCDNathalie Veronelli Eigenmann & VeronelliRamon J. Vias AECQ (Spanish Association)

    Director General : Uta Jensen-Korte

  • Executive Summary Executive Summary

    specific publications and guidance. The website members area hosts a wide range of documents such as guidelines, expert views on relevant regulation and fact sheets, on issues important to the chemical distribution industry.

    Networking : Fecc serves as a platform where members benefit from unrivalled networking opportunities. Fecc develops and maintains close relationships with other industry associations that allow our members to connect with industry leaders and key stakeholders.

    Promotion : Fecc will raise company members profile through its communications tools such as the members section of the newsletter, website and publications.

    Discounts : Members also enjoy reduced rates, for the Annual Congress, seminars and workshops.

    Members

    We strive not only to offer our members a wide range of benefits, but also to serve as plat-form to foster co-operation within our industry. Developing our membership is a priority and absolutely imperative to strengthen our posi-tion as the European voice of the chemical distribution industry.

    In 2014, Fecc welcomed two new company members, CG Chemikalien and 2M Holdings. Founded in Laatzen near Hanover, Germany in 1962. CG Chemikalien, a family-owned business, has continuously evolved and established itself in many markets. 2M Holdings is a leading international chemical distributor and a wholly owned private company headquartered in the UK. 2M Holdings has six branded companies in six world-wide locations : UK, Ireland, Belgium, Poland, Norway and China.

    Fecc and ICCTA

    On May 27, 2014, Fecc Treasurer Peter Skou was elected President of the International Council of Chemical Trade Associations (ICCTA). As member of the Fecc Board, Mr. Skou has skilfully served

    as Fecc treasurer for the past four years, playing a pivotal role in the recent developments of the association. Mr. Skou has acquired vast experi-ence in the industry as Managing Director and part owner of the successful distribution company R2 Group A/S. ICCTA provides a platform where chem-ical distributors from many different countries can meet and exchange information and best prac-tises. Fecc and its national associations actively participate at the ICCTA meetings with the aim to exchange views on practical matters related to Responsible Care/Responsible Distribution/Social Responsibility initiatives.

    REACH

    The preparation for the 2018 registration deadline and the dedicated support to SMEs, the authorisation process, extended Safety Data Sheets (SDS) related issues and the supply chain communication, maintained REACH as an important topic during 2014. In this context Fecc advocates for the simpli-fication and reduction of the overall costs of the process. Fecc is actively involved in the Expert Network on Exposure Scenarios (ENES) platform set up to promote workable solutions and practical improvements for exposure scenarios implementation. Fecc is intensively monitoring the new developments for nanomaterials, polymers and endocrine disruptors which are still under discussion and may impact heavily our industry.

    CLP

    Fecc follows closely the European Commissions activities with regard to the transposition of the 5th revision of the GHS into CLP and the activi-ties related to the harmonisation of information to Poison Centres. The proposal for nitric acid reclassification was a priority topic during 2014 which was successfully tackled thanks to unified industry sectors contributions.

    Seveso

    Fecc follows the discussion on the develop-ment of methodologies to implement article 4 of the Seveso III Directive. Article 4 was newly

    Fecc Business Plan 2015 | 5

  • introduced by Seveso III and it aims at providing exemptions for substances for which it is impos-sible in practice to cause a release of matter or energy that could create a major accident under both normal and abnormal conditions which can reasonably be foreseen.

    Biocides

    To support the implementation of the Biocidal Product Regulation, Fecc updates and advises companies on their obligations and the proce-dure to follow in order to place a product on the market.

    EXCiPACTTM certification scheme

    In 2014, EXCiPACT became a free-standing, not-for-profit association (asbl) under Belgian law. Fecc is a member of the Board and is actively involved in the workings of the certification scheme. Fecc also supports the initiative by hosting and organising the EXCiPACT Training programmes. EXCiPACT certificates have been issued in Canada, France, Germany, The Nether-lands, and Saudi Arabia.

    A group of industry experts from the European Fine Chemicals Group (EFCG), the International Pharmaceutical Excipients Council Europe (IPEC Europe), IPEC Americas, the European Association of Chemicals Distributors (Fecc), and the Pharma-ceutical Quality Group (PQG) are working together on this scheme.

    International Trade

    Feccs International Trade Committee informs and updates its members on European and International chemical trade policy and trends. It provides market oriented information and updates, particularly on emerging markets and regions. The Committee also drafts and circu-lates factsheets containing macro-economic and chemical industry related data in focus regions. The Committee closely monitors issues pertaining to Free trade agreements (FTAs), anti-dumping investigations, sanctions as well as EU imposed restrictions.

    Pharma, Food, Feed and Cosmetics

    Feccs Good Trade and Distribution Practice (GTDP) Committee has actively followed and formulated Feccs positions pertaining to the distribution of pharmaceutical starting materials, APIs and excipients. It also follows all regulatory activity in the food, feed and cosmetics industries, where it monitors European and international initia-tives and works actively to define Good Trade and Distribution Practices for these sectors. The Committee regularly invites external experts to its meetings to update its members on current and emerging issues pertaining to the pharma sector in particular regulatory activities, GMPs and GDPs.

    Responsible Care

    Responsible Care (RC) is and always will be a top priority for Fecc. Fecc will use every occasion to promote RC and the Fecc EU RC programme.

    2013 and 2014 have been years of consolidation as the majority of the company subsidiaries applica-tions have matured and completed the application phase with a TPV assessment. However some of them have demonstrated challenges during imple-mentation.

    The Fecc programme itself has shown a number of areas for improvement : the overall quality manage-ment of the programme should be enhanced and some inconstancies within the current programme text should be resolved.

    Executive Summary

    6 | Fecc Business Plan 2015

  • In order to limit the number of drop outs and increase the overall quality of the programme, Fecc should step up the pace and assist the companies and associations in implementing the programme, where resources permit.

    Product Stewardship

    In 2013, the Product Stewardship Committee went through a substantial change : although the emphasis remains on creating a platform where manufacturers and distributors come together, a new framework of the Committee was adopted with the intent to become a specialist forum, where specific distributor industry issues can be discussed with stakeholders throughout the complete supply chain. This approach has been consolidated during 2014 and will be the main focus of the Committee in the coming years.

    Logistics

    The Logistic Committee held one meeting in 2014. Its main topic was the monitoring of the regula-tory developments at the UN model and regional modal levels. Fecc participated in several initia-tives such as the ECTA work group safe loading and unloading.

    Precursors

    Due to the nature of the activity in this area, the Precursor Committee only meets when there are substantive items to discuss in detail, whilst the committee was relatively active in 2014 there was only the need to meet once with the bulk of the activity being handled on-line or via teleconfer-ence. The Committee and Secretariat monitor the developments in CBRNE, PIC, Dual Use and the explosive and drug precursors regimes.

    Executive SummaryExecutive Summary

    Fecc Business Plan 2015 | 7

  • The results of the 2014 collection (data 2013) show that Feccs member associations represent around 840chemical distributors, around 29,000 employees at over 1,300 sites, handling 31 million tonnes shipped with an industry turnover close to 27 billion Euro.

    Number of Chemical Distributors

    Number of Employees

    Fecc 2014 survey (Data 2013)

    (*) The substantial drop is primarily caused by the drop in employees in Italy (-2300)

    800

    810

    820

    830

    840

    850

    860

    870

    880

    890

    2010 2011 2012 2013

    880

    869

    832

    838

    27.500

    28.000

    28.500

    29.000

    29.500

    30.000

    30.500

    31.000

    31.500

    32.000

    32.500

    2010 2011 2012 2013 *

    30.498

    31.035

    32.158

    29.377

    8 | Fecc Business Plan 2015

  • Fecc 2014 survey (Data 2013)

    Breakdown per country on the number of (Seveso) sites and number of employees

    Members Exports (Company Survey)The main non-EU export markets for 2013 are :

    1. Turkey2. Switzerland3. Russia4. USA

    Fecc 2014 survey (Data 2013)

    B

    38

    CH CZ D DK ES F FIN I IRL NL P S UK0

    1.000

    2.000

    3.000

    4.000

    5.000

    6.000

    7.000

    8.000

    0

    50

    100

    150

    200

    250

    300

    Total # Sites Total # Seveso Sites Total # Employees

    7

    1.059

    10

    408 25

    4

    488

    314

    31

    7.037

    50

    12

    800

    28

    5

    1.316

    166

    37

    3.157

    22

    0

    272

    330

    30

    6.000

    131

    18138

    9

    2.600

    80

    5

    1.000 36

    0

    100

    176

    35

    4.959

    17

    Total #SevesoSites

    Total #Employees

    Export Russia Export Turkey

    ExportSwitzerland

    Export USA

    Export Norway

    Export China Export Africa (others)

    Export Asia (other)

    ExportUkraine

    ExportMaghreb

    ExportBrasil

    ExportSouth America(others)

    Others

    Fecc Business Plan 2015 | 9

  • Members Imports (Company Survey) Figures from 2013 show that the predominant import markets are :

    1. China2. USA 3. South Korea,

    Asia (other), India

    In the next two graphs we asked the National Association members to rate (from 1-very low- to 5-very high-) the sectors supplied and the activities of their members.

    Sectors supplied & Distributor activitiesThe top five sectors being supplied are :

    ,, Chemicals,, Coatings,, Plastics,, Cosmetics,, Paint

    Fecc 2014 survey (Data 2013)

    0%

    10%

    20%

    30%

    40%

    50%

    60%

    70%

    80%

    90%

    100%

    Chem

    ical

    Food

    Feed

    Agroch

    emica

    l

    Pharma a

    pi

    Pharma e

    xcipi

    ents

    Cons

    tructi

    on

    Cosm

    etics

    Plasti

    csPa

    int

    Pape

    r

    Electr

    onics

    Water t

    reatmen

    t

    Textile

    s

    Rubb

    er

    Coating

    s

    Very High High Medium Low Very Low

    Import China

    Import USA

    ImportSouth Korea

    Import Asia(other)

    Import IndiaImport Japan

    Import Taiwan

    ImportSwitzerland Import

    Turkey

    ImportThailand

    ImportCanada

    ImportBrasil

    Others

    10 | Fecc Business Plan 2015

  • The most common activities among the Fecc distributor members remain :

    ,, Distribution,, Warehousing,, Technical support

    Fecc 2014 survey (Data 2013) Fecc 2014 survey (Data 2013)

    0%

    10%

    20%

    30%

    40%

    50%

    60%

    70%

    80%

    90%

    100%

    Distr

    ibutio

    n

    Wareho

    using

    Form

    ulatin

    g

    Blend

    ing

    Re-pac

    kagin

    g

    Re-la

    belin

    g

    Tech

    nical

    supp

    ort

    Very High High Medium Low Very Low

    Fecc Business Plan 2015 | 11

  • Introduction

    The International Trade Committee focuses on issues pertaining to trade with major emerging markets in Asia, South America, Africa, Middle East and Eastern Europe. The Committee focuses not only on exports and imports, but also on issues specific to the chemical distribution sector in these regions.

    Activities & Achievements 2014

    ,, The Committee updated members on trade regimes, embargoes and trade defence instruments :,Analysis of various Free Trade

    Agreements (FTAs) and trade pacts being negotiated.

    ,Monitoring of various embargoes and restrictions for example on, Iran, Syria and Russia amongst others.

    ,, Fecc Representation at the EuroCom-merce International Trade Committee, DG Trade Market Access Working Group on Chemicals, EuroCommerce Exports Working and the EU Russia Regulatory dialogue - subgroup on chemicals.,, Distributor/agent and principal issues :,The Committee focused on various

    issues pertaining to distribution agreements.

    ,, Organised an International Trade meeting on 13 November 2014,

    focusing on embargoes, trade restric-tions and distribution agreements. ,, European Commission consultations,Responded/developing a response

    to the following consultations,E Public consultation on invest-ment protection and investor-to-state dispute settlement (ISDS) in the Transatlantic Trade and Investment Partnership Agree-ment (TTIP).,E A strong European policy to support Small and Medium-sized enterprises (SMEs) and entrepre-neurs 2015-2020 Public consul-tation on the Small Business Act (SBA).,E Public consultation on the Evaluation of the Commercial Agents Directive (86/653/EEC),E Public consultation on the Commissions Stakeholder Consultation guidelines,E Public consultation on the revision of the Commissions Impact Assessment guidelines.

    ,Contribute to the European Commission study on the cumu-lative cost assessment for the chemical industry.

    Work Plan 2015

    ,, Provision of information on emerging markets :,Analysis of economic data from

    different countries and regions

    and providing this to members. Likely regions and countries include Middle East, South East Asia and China.

    ,Presentations on the economic climate, investment opportuni-ties, access to credits, special programmes, chemical asso-ciations and related aspects in emerging markets.

    ,Update members on regulations affecting trade and chemical distribution.

    ,Distribute market studies and other publications available to members.

    ,Organise market focused interna-tional trade meetings.

    ,, Organise chemical trade meetings on a regular basis and attract potential members to attend. ,, Continue work on distributor/agent and principal issues.,, Continue providing regular updates to members on :,Free Trade Agreements (FTAs),Anti-dumping investigations and

    antisubsidy measures,EU regulations on sanctions,Other tariff and non-tariff barriers,, Monitoring the Russia Round Table discussions and the Customs Union.,, Participation in DG Trade Market Access Working Group on Chemicals and the EuroCommerce International Trade Committee.

    International Trade Committee

    Franz Saif

    BTC Europe Chairperson

    mem

    bers

    Joel DSilva FeccDavid Garcia BarcelonesaCarsten Guentner NRCSteve Fannin Omya AG SchweizPavel Kratochvil BarentzMichael Paetzold IMCDClaus Pedersen R2 GroupHeinrich Schrage Lanxess Distribution

    Fanny Torras QuimidrogaNathalie Veronelli Eigenmann & VeronelliJuan Manuel Wilke Campi y JoveOliver Zimmermann TER Group

    12 | Fecc Business Plan 2015

  • SHE Committeem

    emb

    ers

    Michael Ptzold

    IMCD Chairperson

    Douglas Leech CBA (British Association) Vice-ChairpersonOphlie Roblot FeccAlain Berthet BACD (Belgian Association)Henk Boden CaldicPeter Cooper UnivarJacques Declercq BACD (Belgian Association) Ahmed Diboune Azelis GroupHeinz-Werner Dobbertin VCH (German Association)Virgine Fourneau InventecSimona Lai Omya

    Marianne Lyngsaae BrenntagEyck-Michael Poll Ter HellBirthe Oldenborg KB (Danish AssociationRenato Porta AssICC (Italian Association) Gilles Richard UFCC (French Association) Katrin Schindler C.H. Erbslh Heinrich Schrage Lanxess DistributionJan Skov Norby R2 Group Peter Steinbach VCH (German Association) Raoul Tacou BiesterfeldSteffen Voss Aug. HedingerWillem Vriesendorp VHCP (Dutch Association)

    Introduction

    The Safety, Health and Environment (SHE) Committee is an expert group that monitors devel-opments in the areas of safety, health and envi-ronment, evaluates critical developments in the legislative process and works closely with relevant stakeholders. Currently, the Committee focuses on the Regulation on Registration, Evaluation, Authori-sation and Restriction of Chemicals (REACH), the CLP Regulation, the Seveso Directive and the Bioc-idal Product Regulation (BPR).

    Feccs contribution includes joint develop-ment of several guidance documents and offi-cial responses to consultations. The Committee deals with the implementation of REACH, CLP and Biocides through its involvement in the Partner Expert Groups (PEGs) in charge of developing and updating guidance documents e.g. Guidance on Information Requirements and Chemical Safety Assessment (IR&CSA) : Use Descriptor System, Guidance on Active Substances and Suppliers (Article 95 list) under BPR.

    The participation in the Directors Contact Group, at the Competent Authorities on REACH and CLP (CARACAL) and the Expert Network on Expo-sure Scenarios (ENES) enables Fecc members to be actively represented in the decision making processes of the REACH and CLP implementations. The SHE Committee provides input via regular contacts with the European Commission, the Euro-pean Chemical Agency (ECHA) and other industry associations. Fecc is a member of DUCC, the down-stream users platform and of the REACH Cross Sector Group which puts together representatives

    from the entire supply chain in order to resolve registration and authorisation related issues.

    Regarding CLP, Fecc plays an active role in taking part in the discussion on the information require-ments to Poison Centres and in preparing CLP 2015 deadline for reclassification of mixtures.

    Fecc provides advice regarding the implementa-tion of relevant legislations e.g. REACH registra-tion, authorisation and restriction processes, SDS relevant issues, CLP or BPR requirements.

    Monitoring relevant issues and updating the members accordingly is part of the SHE Committees activities; it focuses for instance on emerging and existing chemi-cals legislation outside of Europe, on development of IT tools and on enforcement experience.

    Other issues of priority include the GHS with the 7th and 8th ATP to CLP, the implementation of the Seveso Directive and several initiatives concerning the safety of chemicals. Fecc actively contributed in the discussion on the reclassification of nitric acid.

    Activities & Achievements 2014

    REACH,, Advocate for the simplification and reduction of the overall costs of REACH registration,, Registration :,Gathered Feccs members intentions with

    regard to the 2018 registration deadline,, Exposure Scenarios :,Harmonised format for ES adopted at ENES.

    The use of the harmonised format will increase clarity and better understanding at all downstream level of the supply chain.

    Fecc Business Plan 2015 | 13

  • SHE Committee

    ,Fecc comments included by ECHA in their webpage on advice on safe use of mixtures for formulators and importers to give more recognition to distributors.

    ,, Authorisation,Publication of revised joint industry guid-

    ance on authorisation together with nine industry associations.

    ,Set up a monthly update system to update Fecc members on the substances included on the registry of intention.

    ,Promoted a simplified authorisation approach for substances used under controlled condi-tions such as ADCA, DMF etc.

    CLP,, Scientific advocacy encouraged the European Commission to re-consider nitric acid acute toxicity classification proposal.,, Fecc/Cefic/Eurometaux/DUCC Workshop : How to classify MIXTURES under CLP-Be able to check your software results! 19-20 May, 2014.

    Work Plan 2015

    General,, Prepare Feccs views and contributions to be communicated to the EU institutions and external stakeholders.,, Monitor and advice on the REACH, Seveso, CLP and Biocides implementations.,, Monitor other relevant legislation that has an effect on health, environment or safety, as needed e.g.,worker safety legislation, REACH equivalent in non EU Countries, Indus-trial Emission Directive (IED), Regulation concerning the placing of plant protection products on the EU market.

    REACH,, Raise awareness among Feccs members on the 2018 registration deadline and identify tools and actions to support them. Advocate for the simplification and reduction of the overall costs related to the 2018 registration deadline.,, Monitor the register of intent for substances proposed for harmonised classification, for SVHC and for restriction.

    ,, Member of the DCG : identify solutions for new issues related to the 2018 registration deadline with a special attention to SMEs and represent distributors interests.,, Provide company members with advice regarding use communication and implemen-tation of Exposure Scenarios. ,, Co-organise the upcoming ENES meetings and participate in the ad hoc working groups.,, Participation in the development and update of guidance documents (PEGs),, Monitor the public consultation regarding substance inclusion on the candidate list, restriction and authorisation annexes.,, Further investigate and inform members on the issues related to the communication of authorised substances.,, Monitor enforcement actions at Member State level, identify Members issues and discuss with appropriate bodies.,, Monitor developments related to nanomate-rials, endocrine disruptors and polymers.

    CLP,, Raise awareness regarding the 2015 mixture classification deadline and increase relevant knowledge.,, Continue to follow up the discussion on CLP Article 45 (4) harmonisation of information to Poison Information Centres. ,, Continue to monitor the implementation of GHS within other countries and provide advice accordingly.,, Actively contribute to the mixture classifica-tion methodologies development.,, Monitor developments in GHS to provide early advise on potential issues,, Monitor adoption of GHS in other jurisdictions

    Biocides,, Join the Cefic European biocidal product forum,, Organise a workshop regarding the BPR imple-mentation,, Monitor development of in-situ biocides debate,, Monitor biocidal active substance approval process

    14 | Fecc Business Plan 2015

  • Responsible Care Committeem

    emb

    ers

    Robert Stuyt

    VHCP (Dutch Association) Chairperson

    Introduction

    Responsible Care (RC) helps the chemical industry globally to operate safely and with care for future generations. Through the sharing of information and a system of checklists, performance indicators, action plans and verification schemes, Responsible Care enables the industry to demonstrate how its health, safety, security and environmental perfor-mance has improved over the years. The Respon-sible Care companies upgrade existing policies and implement new ones to keep up with and exceed an ever changing regulatory environment; the aim is to have continuous improvement in place.

    Responsible Care requires companies to be open and transparent with their stakeholders, ranging from local authorities and government to the media and of course the general public whilst maintaining their security commitments.

    Activities 2014

    Fecc organised four RC Committee meetings in order to establish a platform for RC coordinators and RC managers to interact and share best practices.

    During the first half of the year a workgroup was established to revise the Fecc EU RC Programme. The objective was to :

    ,, Make the programme more transparent and consistent ,, Create the possibility to use non-ESAD assess-ment schemes to increase flexibility of usage of the programme.

    ,, Create a series of quality criterias in order to evaluate the programme and in order to benchmark non-ESAD assessment schemes.

    In May, the workgroup finalised the document and the RC Committee was asked to make final comments. The revised programme was sent to Cefic for approval.

    With regards to the Fecc EU RC Companies, in 2014 two more companies applied for the programme and we are expecting to receive five more by the end of the year. In total there are now 13 distributor companies in the programme.

    Work Plan 2015

    Fecc commits to the following RC objectives for 2015

    1. Fecc will look into the possibility to promote the programme more intensively towards stakeholders.a. Perform a stakeholder analysis to identify

    all stakeholdersb. Work out a communication programme for

    promotion of RC based on the clear advan-tages of implementing an RC programme

    2. List and benchmark the existing National Association programmes in order to establish best practices throughout Europe.

    3. Set up an internal Fecc workgroup in order to discuss the way forward regarding RC for distributors

    4. Set up an internal Fecc workgroup in order to discuss the way forward regarding RC for distributors

    Ahmed Diboune Azelis Vice-chairpersonJan Thienpont FeccRalph Alberti VCH (German association)Maria Almenar Martin AzelisCatarina Carvalho GROQUIFAR (Portuguese association)Jacques Declercq BACD (Belgian association)Melanie Gay UFCC (French association)Vrter Gomes GROQUIFAR (Portuguese association)Phil Hockaday UnivarPavel Karas SCHOD CZ (Czech association)Terhi Kuljukka-Rabb TKL (Finnish association)Simona Lai OmyaJakob Lamm Zeuthen KEMI&LIFE SCIENCE (Danish association)Sjoerd Looijs Cefic

    Lourdes Luque AECQ (Spanish association)Marielle Martiny SolvayPeter Newport CBA (British association)Marja Ola TKL (Finnish association)Michael Ptzold BrenntagMatt Pollock IACI (Irish association)Renato Porta AssICC (Italian association)Thomas Puehringer BrenntagGilles Richard UFCC (French Association)Steffen Saecker SAFECHEMKatrin Schindler C.H. ErbslhPatrick Vandenhoecke SolvayHeinrich Van Megen BrenntagWim Vermeylen BACD (Belgian Association/IMCD)Gran Wall IKEM (Swedish association)Dorota Zakrzewska HSH Chemie

    Fecc Business Plan 2015 | 15

  • This graph shows that general RC implementation level is increasing year after year. The average level of RC implementation throughout Europe for 2013 is 65.28 %

    This second graph shows the implemen-tation in Europe by country and shows the result from 2009 to 2013. We see an increased implementation level in Denmark, Finland, France, Portugal and Spain.

    A decrease in imple-m e n t a t i o n l e v e l can be observed in Sweden and Germany.

    The rest of Europe remains stable at a high level.

    Responsible Care Committee

    Fecc RC survey 2014

    RC IMPLEMENTATION *

    (*) No data from Swit-zerland and Austria is available

    58%

    59%

    60%

    61%

    62%

    63%

    64%

    65%

    66%

    67%

    68%

    69%

    2009 2010 2011 2012 2013

    62%

    67% 67%

    68%

    63%

    0% 20% 40% 60% 80% 100%

    B (BACD)

    CZ (SCHOD)

    D (VCH)

    DK(KEMI&LIFE SCIENCE)

    ES (AECQ)

    F (UFCC)

    FIN (TKL)

    I (AssICC)

    IRL (IACI)

    NL (VHCP)

    P (GROQUIFAR)

    S (IKEM)

    UK (CBA)

    20132009

    16 | Fecc Business Plan 2015

  • Responsible Care Committee Responsible Care Committee

    LTI RATE 2013 (BY COUNTRY) *

    If we look at the LTI- Rate for 2013 (# Work Accident-with loss of time more than 3 days x 1.000.000/ # worked hours), with an average level for Europe set at 5.47.

    AVERAGE LTI EVOLUTION (2010-2013)

    (*) No data from Swit-zerland and Austria is available

    0

    1

    2

    3

    4

    5

    6

    7

    8

    9

    10

    11

    12

    13

    14

    B (BAC

    D)

    CZ (S

    CHOD

    )

    D (V

    CH)

    DK (K

    EMI&

    LIFE S

    CIENC

    E)

    ES (A

    ECQ)

    F (UF

    CC)

    FIN (T

    KL)

    I (As

    sICC)

    IRL (

    IACI)

    NL (V

    HCP)

    P (GRO

    QUIFA

    R)

    S (IKE

    M)

    UK (C

    BA)

    7,70

    11,66

    10,11

    3,57 3,53

    13,58

    0,67

    2,73

    5,68 5,68

    2,40 2,131,68

    7,00

    15,89

    13,28

    5,47

    0

    2

    4

    6

    8

    10

    12

    14

    16

    18

    2010 2011 2012 2013

    Fecc Business Plan 2015 | 17

  • Product Stewardship Committee

    Introduction

    The Product Stewardships (PS) Committee brings together representatives of the chemical distribu-tion industry and the main European chemical manufacturers holding Feccs associate member-ship. The aim is to discuss, develop and coordinate common initiatives on matters that concern the complete life cycle of a product.

    Every year the Committee members select a hot topic for the distributor community. The complete working year of the Committee is mainly devoted to this issue.

    Activities 2014

    On September 17, Fecc hosted its second Product Stewardship workshop which focused on Food Safety (Food Safety : How to Comply as a Chem-ical Distributor).

    The workshop was hosted by Solvay and was a success with about 60 participants.

    The workshop saw some very interesting presen-tations on the following topics :

    ,, Possible applications of chemicals in the food industry (Cefic),, Existing regulatory Framework and legal reper-cussions for chemical distributors (Mayer Brown),, Quality Standards applicable in the food industry (A+Quality),, EU regulatory perspective (DG Sanco),, Case studies presented by (Azelis, Univar, A+ Quality)

    Work Plan 2015

    Following the workshop on chemicals in the food supply chain, there will be some additional work performed in the form of a guidance document for non-regulated chemicals in food applications.

    End of 2014/beginning of 2015 a new topic will be selected by the Product Stewardship Committee. This topic will once again serve as a focal point for the PS Committee to work around.

    mem

    bers

    Jan Thienpont FeccMaria Almenar Martin AzelisSbastien Gallet Cefic/ECSAVronique Garny CeficSimona Lai OmyaMarielle Martiny SolvayFerdinand Pree SAFECHEM

    Patrick Vandenhoeke SolvayHeinrich Van Megen Brenntag

    Incagli Michle

    IMCD Chairperson

    18 | Fecc Business Plan 2015

  • mem

    ber

    s

    GTDP Committee

    Frank Milek

    Aug. Hedinger GmbH & Co KG Chairperson

    Catherine Martin Univar Vice-chairpersonJoel DSilva FeccRalph Alberti VCH (German Association)Maria Almenar Martin AzelisPauline Ayres AzelisFranziska Buck BiesterfeldAnaide Burel UFCC (French Association)Monica Comajuan QuimidrogaDaniela Fermo AssICC (Italian Association) Marta Ferrer Monsech Campi y JovUlrike Gerster Barentz

    Laszlo Kegl Forum Products Ltd (Barentz)Douglas Leech CBAFranois Minec VeloxAnneliese Neuser HarkeJan Skov Norby R2 GroupHanna Puetz BrenntagGilles Richard UFCC (French Association)Stephan Rynka IMCDHenk-Jan Schuuring Barentz Christoph Sonntag AzelisClaudio Zanotto AssICC (Italian Association)

    Introduction

    The Good Trade and Distribution Practices (GTDP) Committee formulates Feccs posi-tions in relation to distribution in sectors such as pharmaceuticals, cosmetics, food and feed. The Committee also facili-tates GMP and GDP education for Feccs Members by organising technical semi-nars and conferences on related issues.

    Further, the Committee is a stakeholder in relevant meetings and working groups with the European and international regu-latory authorities, including the European Medicines Agency (EMA), theEuropean Commission and the European Food Safety Authorities (EFSA).

    Activities & achievements 2014

    ,, The Committee closely monitored all activities pertaining to the Directive on falsified medicinal products and commu-nicated this to the members.,The Committee circulated updates,

    communications and various published reports to the members.

    ,In 2013, the Committee responded to the European Commission consul-tation on the revision of the guide-lines on GMP for Medicinal Prod-ucts : Part 1 Chapter 5 : Production. The final version released in 2014 included several of the Commit-tees suggestions and comments.

    The Committee further distributed an updated document highlighting the changes and revisions.

    ,Monitored activity pertaining to (a) Guidelines for the risk evaluation for ascertaining the appropriate GMP forpharmaceutical excipients and (b) Guidelines on the principles of GDP for Active substances for medicinal products for human use.

    ,, Organised a Regulatory and Quality Standards Symposium on March 26, 2014, which was well attended. Speakers from the European Commis-sion, European associations and law firms, as well as company executives presented and discussed a wide array of issues pertaining to Regulation, Safety and Quality standards in the areas of pharmaceuticals & excipients, food & feed additives and cosmetics.,, Fecc actively participates in the EXCi-PACTTM Certification scheme.,EXCiPACTTM has become a free-

    standing, not-for-profit association (asbl) under Belgian law. The Arti-cles of the Association were signed on January 29, 2014, in Cannes.

    ,Fecc is a member of EXCiPACTTM

    asbl and is represented in the Board. Feccs representative also acts as EXCiPACTTM treasurer.

    ,EXCiPACTTM cert i f icates have been issued in Canada, France, Germany, The Netherlands, and Saudi Arabia.

    ,Hosts and coordinates EXCiPACTTM

    training programmes.,, Contributed to an AT Kearney study on pharmaceutical chemicals distribution,, Monitoring all relevant legislation and related activities pertaining to Food, Feed and Cosmetic products. The Committee regularly invited members and external experts to make presen-tations on regulatory updates.

    Work Plan 2015

    ,, Systematic monitoring of all develop-ments pertaining to pharmaceutical ingredients and excipients as well as those related to the implementation of the Directive on falsified medicinal products. ,, Continued involvement in the EXCi-PACTTM certification scheme.,Actively participate and contribute

    to the scheme and continued implementation.

    ,Assist and continue supporting EXCiPACTTM training programmes.

    ,Continued cooperation with IPEC, EFCG and other stakeholders.

    ,, Review and follow up on all regula-tory and legislative developments pertaining to pharmaceuticals, Food, Feed and Cosmetics.,, Organise a training course or sympo-sium on a hot topic based on the objectives of the committee.

    Fecc Business Plan 2015 | 19

  • Precursors Committeem

    emb

    ers

    Jan Thienpont FeccMaria Almenar Martin AzelisAnade Burel UFCC (French Association)Douglas Leech CBA (British Association) Peter J. C. Newport CBA (British Association) Jos M. Plana Quimidroga S.A.

    Introduction

    The Precursors Committee is a group of experts that shares information and discusses the latest European and global developments in the fields of drug precursors, explosives precursors, the Chemical, Biological and RadioNuclear (CBRNE) Action Plan with focus on the chemical subgroup and Prior Informed Consent Procedure (PIC).

    The Committee usually meets three times a year (if there is a need) and has both an active circulation of information and is engaged with increasing frequency in the formulation of Feccs positions and technical advocacy.

    Activities 2014

    2014 was a year with less activity by the Euro-pean Commission. Fecc therefore organized just one Committee meeting in February 2014. If there is a need for a second Precursors Committee, there will be a conference call organised.

    Explosive PrecursorsFecc, in association with the CBA, is heavily involved in the Standing Committee on Explosives Precursors (SCEP). The SCEP works on reducing the risk of misuse of certain chemicals to fabricate home-made explosives. The SCEP assists the Euro-pean Commission in its work to further reduce the risks related to the misuse of such precursors.

    The European Commission Action Plan promotes other preventive measures, such as the tight-ening of security along the entire supply chain of commercial explosives in the EU, including in production, transport, storage, commercialisation and final use. This group has finalised the draft guidance on precursors relating to Regulation (EU)

    No 98/2013, which is now officially published. Its development was monitored by the Committee. The document in wide parts is based on the known FECC Model Agreement. Of special interest for the distribution sector is its section D, which gives special guidance to the reporting of suspi-cious transactions, disappearances and thefts according to Art. 9 of the Regulation. There is also a definition when a mixture has to be considered to be an attractive explosive precursor.

    Drug PrecursorsRegulation (EU) No 1259/2013 of the European Parliament and of the Council of November 20, 2013 amending Council Regulation (EC) No 111/2005 laying down rules for the monitoring of trade between the Community and third coun-tries in drug precursors and Regulation (EU) No 1258/2013 of the European Parliament and of the Council of November 20, 2013 amending Regula-tion (EC) No 273/2004 on drug precursors have been published in the Official Journal of the Euro-pean Union.

    The most important changes for chemical distrib-utors are :

    ,, The substance alpha phenylacetoacetoni-trile, better known as APAAN (with CN Code 2926 90 95 and CAS No 4468 48 8) has been scheduled in Category 1 of the Annex to Regu-lation (EC) No 111/2005.,, Acetic Anhydride (AA) is included in the new subcategory 2A of Annex I to Regulation (EC) No 273/2004 to allow increased control of its trade. End-users of subcategory 2A substances will have to register. However, this new requirement will only become obligatory as of June 30, 2015

    Ralph Alberti

    VHC (German Association)Chairperson

    20 | Fecc Business Plan 2015

  • Precursors Committee Precursors Committee

    ,, In considering whether to grant a license or a registration, the competent authority shall take into account the competence and integ-rity of the applicant, in particular the absence of any serious infringement or repeated infringements of legislation in the field of drug precursors and the absence of a record of any serious criminal offence.,, The competent authorities of each Member State shall prohibit the introduction of consignments of non-scheduled substances into the customs territory of the Union or their departure from it where there is sufficient evidence that those substances are intended for the illicit manufacture of narcotic drugs or psychotropic substances.,, Additionally, each Member State may adopt the measures necessary to enable its compe-tent authorities to control and monitor suspi-cious transactions involving non-scheduled substances.

    Chemical Biological Radiological Nuclear and Explosive (CBRNE )During 2014, the focus of the CBRNE stakeholder meetings and subgroup meetings was primarily on detection (being the priority policy area) and on the vast amount of projects initiated by the European Commission (+70 projects). Some of the projects will have a very long duration time.

    There is an intention to develop Risk Acceptance Criteria (RAC) in the field of security.

    World Customs Organisation (WCO ) Global Shield seminar October 2014The objective of the seminar was to raise awareness, discuss best practices and increase

    collaboration between customs administrations and other government agencies in the field of explosive precursor chemicals that can be used for manufacturing IEDs (Improvised Explosive Devices).

    Achievements 2014

    ,, Promotion of the Fecc Model Agreement with regards to ICCTA and the WCO.

    Work Plan 2015

    Fecc commits to the following objectives for 2015 :

    Explosive Precursors ,, Monitoring the implementation of the new Regulation on Explosive Precursors,, Liaise with industry stakeholders in the devel-opment of positions and sharing best prac-tices,, Promote the Fecc Model Agreement where possible,, Continue monitoring the EXPEDIA project

    Drug Precursors ,, Continue monitoring the work of the European Commission Drug Precursor Working Group,, Providing information to the European Commission on the impact of the possible revision of the drug precursors and repre-senting the distributor industry position.,, Inform members of the pending revisions to the regulations.

    CBRNE ,, Broaden and deepen good contact and discus-sions with the European Commission,, Continue monitoring and impacting the CBRN Advisory Group and Chemicals sub-group

    Fecc Business Plan 2015 | 21

  • Logistics Committee

    Introduction

    The Logistics Committee monitors developments in EU and international legislation concerning the safe transport and handling of dangerous goods as well as transport security related issues. Some of the regulations followed by this Committee are : the UN Model Rules, ADR/RID/IMDG and other issues dealing with the carriage of dangerous goods.

    The Committee works directly with relevant industry groups such as CEFIC (European Chem-ical Industry Council), IRU (International Road Unit) and ECTA (European Chemical Transport Association).

    Activities 2014

    ,, Fecc hosted the Logistics Committee twice in 2014.,, At the UN level Fecc monitors the develop-ments of the UN Subcommittee of Experts for Transport of Dangerous Goods.,, Participate at the European Commission DG Move meetings on the transport of dangerous goods

    ,, Participation in EU Commission LANDSEC meet-ings, involving security related issues in land transport.,, Involvement with stakeholders, cooperation and exchange of experiences with relevant international associations (INDA, Cefic, ECTA),, The Fecc secretariat participated in the revi-sion of the SQAS Rail Module,, Fecc promoted the Best Practice Guide for Safe (UN) Loading of Freight Road Vehicles in the newsletter and on the Fecc website.

    Achievements 2014

    Finalisation and distribution of the Fecc/ECTA/Cefic Best Practice Guide for Safe (UN) Loading of Freight Road Vehicles.

    Work Plan 2015

    ,, Implement an administrative process to handle the vast number of official documents in order to inform the Logistics Committee members in an efficient and pragmatic way,, Fecc will seek to enhance sector and partner attendance through an interesting agenda and by inviting the transport sector.

    mem

    bers

    Peter J. C. Newport

    CBA (British Association) Chairperson

    Jan Thienpont FeccMaria Almenar Martin AzelisAnaide Burel UFCC (French association)Frank Braeckmans ExxonJacques Declerq BACD Belgian associationIgnace Dejager BrenntagSerge Dewolf BACD (Belgian association)Vanessa Garenton DKSH

    Jonathan Garlick BPPeter Steinbach VCH (German association)Hugo Van der Boom Lyondell Chemie

    22 | Fecc Business Plan 2015

  • Robert Stuyt

    VHCP (Dutch Association) Co-chairperson

    ESAD Steering Committee

    Victor Trapani

    CEFIC Co-chairperson

    Jan Thienpont FeccFrank Braeckmans ExxonSbastien Gallet Cefic/ECSAJonathan Garlick BPUta Jensen-Korte FeccPeter J. C. Newport CBA-British associationLeo Ruppert Shell

    Peter Steinbach VCH (German association) Patrick Vandenhoeke SolvayHugo Van der Boom Lyondell ChemieMaayke Van Noort Dow

    Introduction

    The Fecc ESAD Steering Committee operates in partnership with Cefic. The aim is to oversee the ESAD module of the SQAS system and identify then resolve any issues of concern. The Steering Committee is responsible for ensuring the integ-rity of the ESAD module and encourages the ESAD principles being followed by all involved parties.

    Activities 2014

    ,, Monitor and input to the revision of the SQAQ ESAD module.,, Status and progress of the ESAD system,, Encourage the use of ESAD or equivalent system in the Fecc EU Responsible Care scheme,, Promotion of the active use of the ESAD scheme by distributors and chemical companies,, The Committee has considered and decided upon the addition of CSR questions in the ESAD Module,, Fecc has participated in the revision of several SQAS modules

    Activities & Achievements 2014

    ,, The Fecc Secretariat has actively been involved in the adoption of a new SQAS RAIL questionnaire, the questionnaire was finalized in July 2014.,, Complete revision of the ESAD 2011 ques-tionnaire, the questionnaire is now ready for implementation in January 2015. The most predominant changes were :,Integration CSR (Corporate Social Responsi-

    bility) based on TfS,Security : the incorporation of enhanced

    questions addressing EU Commission requirements

    ,Security : Adoption of questions already used in SQAS Transport

    Work Plan 2015

    ,, Fecc will promote SQAS/ESAD as the preferred assessment scheme for evaluating the respon-sible care progression at any given site.,, Monitoring the assessor accreditation

    Fecc Business Plan 2015 | 23

  • Fecc ESAD statistics (data 2013)

    The two graphs below show the year to year trend of the number of active SQAS assessment reports, generated per module and the number of ESAD consultations on active reports. The last graph gives info on the number of available ESAD assessors per country.

    NUMBER OF ESAD REPORTS PER SECTION

    NUMBER OF ESAD REPORTS CONSULTATIONS

    ESAD Steering Committee

    0

    20

    40

    60

    80

    100

    120

    140

    (Di) DistributorStandard Activities

    (S) Site Assessment (Cs) ChlorinatedSolvents

    (F) Food, Cosmeticand Pharma

    (G) Good Trade andDistribution Practices

    2012 2013 1/7/13 - 1/7/14

    98

    115

    91

    72

    100

    75

    34

    44

    29

    47

    33 31

    20 23 21

    0 50 100 150 200 250 300 350

    2008

    2009

    2010

    2011

    2012

    2013

    1/7/13 - 1/7/14

    294

    323

    289

    284

    150

    328

    207

    24 | Fecc Business Plan 2015

  • ESAD Steering CommitteeESAD Steering Committee

    NUMBER OF ESAD ASSESSORS PER COUNTRY

    DE - 10ES - 9

    NL - 7

    IT - 5

    FR - 3GB - 3 AT - 2 BE - 2

    FI - 2

    PL - 2CH - 1

    CZ - 1

    DK - 1

    GR - 1

    HU - 1

    IE - 1

    PT - 1

    SE - 1

    SI - 1

    Other - 7

    Fecc Business Plan 2015 | 25

  • AUSTRIA

    Wirtschaftskammer sterreich (WKO), Bundesgremium des Handels mit Arzneimitteln, Drogerie- und Parfmeriewaren sowie Chemikalien und Farben

    BELGIUM

    Belgian Association of Chemical Distributors (BACD)

    CzECH REPUBLIC

    Svaz Chemickych Obchodnku A Distributoru Cesk Republiky (SCHOD CR)

    DENMARk

    Kemi & Life Science (KB)

    FINLAND

    Teknisen Kaupan ja Palveluiden yhdistys (TKL)

    FRANCE

    Union Franaise du Commerce Chimique (UFCC)

    GERMANY

    Verband Chemiehandel (VCH)

    IRELAND

    Irish Association of Chemicals & Ingredients (IACI)

    ITALY

    Associazione Italiana Commercio Chimico (AssICC)

    THE NETHERLANDS

    Verbond van Handelaren in Chemische Producten (VHCP)

    PORTUGAL

    Associao de Grossistas de Productos Qumicos e Farmacuticos (GROQUIFAR)

    SPAIN

    Asociacin Espaola del Comercio Qumico (AECQ)

    SWITzERLAND

    Scienceindustries (SGCI)

    SWEDEN

    Innovations- och kemiindustrierna i Sverige (IKEM)

    UNITED kINGDOM

    Chemical Business Association (CBA)

    Associate members

    AkzoNobel Chemicals(Until December 2014)BASFDow CorningDow EuropeEvonikFuchs KimyaMillchem(From January 2015)Shell Chemicals EuropeSolvay SQM EuropeWacker Chemie(Until December 2014)

    2M HoldingsAlgolAzelisBarentzBiesterfeldBrenntagBTC Speciality Chemical DistributionCaldicCampi y JovCGChemikalienC.H. ErbslhCornelius GroupDKSHEigenmann & VeronelliGrolman GroupHarke GroupAug. HedingerHSH Chemie

    IMCD GroupInventecJSC RuskhimsetKrahn ChemieLanxess DistributionNordmann RassmannOmyaQuimidrogaQuimitecnicaR2 GroupSAFECHEM SteraChemicalsSTOCKMEIER GroupTelkoTennants DistributionTer GroupUnivar EuropeVELOX

    VWR International

    National Associations

    Company members

    26 | Fecc Business Plan 2015

  • Fecc Business Plan 2015 | 27

  • www.fecc.org

    European Association of Chemical Distributors (Fecc)

    Rue du Luxembourg 16B

    B-1000 Brussels, Belgium

    Tel : +32.2.679.02.60

    Fax : +32.2.672.73.55