Safety

The continuous improvement of a safe work environment is both a high priority and a key component of Covestro’s corporate responsibility and corporate culture. The company’s top priorities include preventing injuries, equipment breakdowns, and transportation incidents, as well as preserving the health of our employees in the workplace and during work-related activities. This also applies to partner companies (contractors) who work for our company within the scope of operational activities. Detailed rules and regular checks are instrumental in meeting these goals, as are safe production processes, plants, and transportation. Another priority is protection of the environment, and safe handling and use of products as part of our product stewardship. In addition, we have transferred the insights obtained from the SafeGuard safety program into our integrated management system in which we address all aspects of safety of importance to Covestro in a comprehensive and global manner.

Safety incidents that – under other circumstances – could have led to a High Potential Event (HPE) are examined using a set of criteria we have defined that includes their potential effects. Events classified as HPEs are thus treated as comparable to events that have actually occurred; they require a detailed cause analysis and must be communicated. Promoting safety awareness among employees is essential for minimizing hazards during day-to-day operations. In the year 2019, the Team Resource Management training program was set up to further increase safety awareness among our staff. Due to the coronavirus pandemic, this in-person training could not be held in fiscal 2020 and is expected to be continued in 2021.

The CEO Safety Award was awarded for the twelfth time in the reporting year. All employees were once again called upon to submit suggestions for improving safety. The ideas submitted were evaluated by a jury of in-house experts, and our CEO presented awards to the winners at the virtual Covestro Safety Day in September 2020.

Occupational Health and Safety

An integrated information management system (IIMS) implemented throughout the Group exists for reporting and processing work-related accidents and illnesses, as well as potential hazards. The classification and documentation follows the U.S. OSHA Standard 1904 “Recording and Reporting Occupational Injuries and Illness.” The IIMS makes it possible to identify trends in a timely manner so that corresponding short-term corrective and long-term improvement measures can be implemented if necessary. Covestro’s safety experts, supported by external expertise if needed, analyze the background circumstances and the consequences. The results of the root cause analysis conducted after an incident occurs and the corrective measures taken are published throughout the Group in order to raise employees’ safety awareness. As a result, everybody can better assess comparable hazards and situations and proactively remedy them. In the reporting year, the topic of electrical safety was identified as a priority and given the requisite attention with a global campaign. Furthermore, the working group on human-machine interaction launched in the year 2019 continued to meet.

Covestro processes documentable workplace accidents and illnesses involving the company’s own staff and contractors as part of the recordable incident rate (RIR) and lost time recordable incident rate (LTRIR), as per OSHA 1904. The RIR is calculated as a ratio of the total number of documentable workplace accidents and illnesses to hours worked (standardized to 200,000 working hours per year). The LTRIR is calculated as a ratio of lost time in days to the same hours worked figure. We calculate the number of hours worked by our employees based on the number of employees in the Group and multiply this figure at country level by the average working hours in the member states of the Organisation for Economic Co-operation and Development (OECD) and the International Labour Organization (ILO). If no OECD or ILO data is available, then we use the average number of hours worked at Covestro.

Due to the coronavirus pandemic, approximately 684,000 fewer hours were worked in fiscal 2020. This was taken into account in calculating the incident rates. The reduction in working hours was primarily attributable to government-mandated site closures and the research facilities affected by the home office regulations.

The number of hours worked by our contractors is calculated using a methodology that includes various categories for recording working hours, broken down by electronic or manual timekeeping or obtained using supplier invoices. The figure can also be calculated based on valid assumptions (estimates). At sites with fewer than 50 Covestro employees, no contractor working hours are counted, so these are not included in the incident rates calculation. We apply controls and other measures at the global level as well as individual site level to prevent possible errors in calculating contractor working hours. Implementation of the new system continued in fiscal 2020.

In the fiscal year 2020, we documented 29.5 million total hours worked (THW) for our employees (previous year: 31.1 million THW). During the same period, contractors reported 16.7 million THW (previous year: 20.2 million THW). This results in the following rates according to OSHA:

We work tirelessly to keep the incidence of accidents as low as possible in the future as well. Implementation of the SafeGuard safety program and introduction of the ISO 45001 standard provided fresh momentum for our efforts toward safety in the workplace. This was an important step for us toward meeting our goal of zero accidents. In the reporting year, workplace accidents involving our employees declined to 35 (previous year: 46), improving our employees’ RIR by 0.05 points. In contrast, the RIR of our contractors’ employees rose by 0.05 points.

We are facing enormous health and safety challenges due to the coronavirus pandemic as well. Our crisis management teams at the sites countered these with a range of measures. This effort even received recognition from outside the company from the European Chemical Industry Council (CEFIC). We were awarded a Responsible Care™ prize in the “Protecting Workers and the Workplace” category for our health and safety measures during the coronavirus pandemic. The Corporate Security function was the central point for consolidating information on country-specific conditions and reporting to the Board of Management. In this way, we were able to fulfill the requirements of the pandemic plan developed and implemented by Covestro.

Process and Plant Safety

We aim to ensure the safety of processes and plants in a way that avoids unacceptable risks to our employees, our neighbors, and the environment. We therefore conduct extensive, systematic safety inspections at regular intervals. An early indicator for all Covestro plants is the Loss of Primary Containment (LoPC) indicator, which is uniform throughout the world and is integrated into the Group’s safety reporting.

Since the year 2019, Covestro has applied the German Chemical Industry Association’s (Verband der Chemischen Industrie, VCI) guidelines on documenting plant safety performance indicators. The new reporting criteria are thus aligned with the updated and globally harmonized definition by the International Council of Chemical Associations (ICCA). A LoPC event comprises

• The release of chemicals classified according to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) exceeding the defined volume thresholds within one hour,
• A reportable injury according to OSHA criteria to an employee or contractor as a result of product release or the release of energy,
• The release of energy (e.g., fire, explosion) that leads to damage with direct costs totaling more than €2,500,
• An evacuation officially declared outside the plant.

We use the LoPC incident rate (LoPC IR) to determine the number of LoPC incidents per 200,000 TWH per year by Covestro employees and contractors. In the year 2016, the ICCA adjusted the volume thresholds used to identify incidents and published these changes, which are binding for its members starting in the year 2020. We applied these volume thresholds at Covestro in the year 2019 so that our statistics would be comparable within the chemical industry and the benchmark. After the adjustments were made, the volume threshold for chlorine, for example, is now one kilogram instead of the original five kilograms. The considerably lower volume thresholds mean that less significant incidents have been systematically documented and investigated as LoPC events since the year 2019. In the reporting year, our LoPC IR was 0.64 (previous year: 0.66).

Every LoPC incident as well as minor and near-miss incidents are carefully analyzed to determine their causes, and the results and corrective actions taken are publicized throughout the Group. The criteria (e.g., low thresholds or non-hazardous substance releases) were selected so that even releases of substances or energy that have no impact on employees, neighbors, or the environment are systematically recorded. This contributes to maintaining the integrity of our facilities. The global exchange of experiences relevant to safety is intended to help maintain the existing high standard of procedural and plant safety within the company. Globally binding standard processes and their uniform implementation also contribute to this effort, which led to the rollout of a mandatory IT application for technical change management at key production sites in fiscal 2019.

Safety at Work

The safety of employees, plants, data, and information as well as uninterrupted workflows and processes are particularly important to Covestro. This is why Covestro’s safety strategy systematically focuses on meeting these safety targets. The corresponding duties and responsibilities are assigned to various departments of the responsible corporate functions. The Corporate Security, Information Technology, and Production Management functions therefore have special authority to effectively counter current and future risks and threats, especially those that are virtual or digital. Decision-making and management bodies focusing on risk, compliance, and crisis management as well as on information security management have been established.

Environmental and Transportation Safety

We work continually toward maximum safety during transportation of our products. We report all incidents at all sites operated by Covestro worldwide in line with our internal directives. These are documented according to defined criteria such as quantity of loss of containment, material hazard class, degree of personal injury, and blocked transportation routes. In the case of certain hazardous materials, we record and categorize all leaks starting with as little as five kilograms, according to our Corporate Commitment. Global events on transportation safety are held at regular intervals. Here, corrective measures are developed and implemented based on actual incidents, and tried-and-tested approaches are exchanged.

Product Stewardship

To Covestro, product stewardship means comprehensively evaluating health, safety, and environmental risks in connection with the use and handling of our products. We want to ensure that our products are safe throughout their entire life cycle – from research to production and marketing to their intended use by the customer and all the way to disposal.

Monitoring the quality of our products and their suitability for particular applications is anchored in our operational units. Safe transportation, qualification for specifically regulated applications, and marketability are centrally managed at Covestro, as is the obligation to report to the Board of Management on these matters.

The safe use and application of our products have high priority. It is very important to us to communicate product safety information transparently and comprehensively. In addition to the documents required by law, we therefore provide supplementary information and offer training as part of the global product strategy of the InterICCA. Furthermore, experts throughout the company work closely with suppliers, customers, industry associations, and the public. Covestro thus aims to ensure the effective communication and observance of health, safety, and environmental information along the entire supply chain.

Management of product stewardship

Product stewardship involves both compliance with statutory requirements and voluntary commitments. Here we also take into account the so-called precautionary principle as explained in Principle 15 of the Rio Declaration of the United Nations and communication COM(2000) 1 of the European Commission. This important means of protecting consumers and the environment within the context of risk management may be used in special cases in which, according to an objective and comprehensive scientific evaluation, material or irreversible harm to people and the environment may occur, but the risk of this cannot be determined with sufficient certainty. In this regard, we follow the corresponding principles of the European Commission when applying the precautionary principle. These include especially the proportionality of the measures taken, an examination of the benefits and the costs of all relevant options, as well as the review of the measures taken in light of new scientific developments. Arbitrary decisions cannot be justified by invoking the precautionary principle.

As a contribution to the safe handling and use of chemicals, risk assessments are carried out applying recognized scientific principles such as those described by the European Chemicals Agency (ECHA) in its Guidance on Information Requirements and Chemical Safety Assessment. A determination is made based on a hazard assessment and exposure estimation as to which additional information is required for the risk characterization of a product.

All product groups at Covestro undergo a multiple-step product assessment process. At first, we identify chemicals that are subject to statutory regulations and document the corresponding regulations. We then examine the risk potential of our products. During this process, we also identify substances for which only limited use or marketing are permitted based on the applicable laws and regulations. These include, for example, Substances of Very High Concern (SVHC) as classified in accordance with the European Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and substances covered by the European regulation on greenhouse gases. Substance compositions in all regions are checked with the help of IT systems against lists of regulated substances so that noncompliance with regulatory requirements is identified reliably. Should the assessment or new findings reveal that it is not safe to use a certain chemical, we take the necessary risk mitigation measures. Those can range from technical measures such as protective gear and revised application recommendations to the withdrawal of support for a certain application or the substitution of a substance. In this case, an adequate replacement must be sought which can be produced in an economical and technically feasible way. Finally, we produce safety data sheets and labeling for all chemicals in up to 40 different languages, including chemicals that are not subject to any legal obligation. In this respect Covestro also exceeds the statutory requirements by making these safety data sheets publicly available.

We collect, document, and analyze all information about the safe and compliant use of our products in a global information system, which provides the basis for further improvements. This includes product monitoring and reporting on product-related and compliance incidents. Our global regulations for the Group contain rules and guidance on when and how this information is to be used. For example, this has helped us improve the information on the safe handling of our products and provide customers with specific training. Furthermore, workshops and online training sessions for our employees contribute to solidifying the understanding and importance of product stewardship in the company.

For fiscal 2020, we know of no material incidents of noncompliance with regulations or voluntary codes – either concerning the health and safety impacts of products and services, or relating to product information and labeling.

The optimization of products and processes is an ongoing task of the chemical industry and is integral to our commitments as part of the Responsible Care™ initiative. This is an initiative by the chemical industry that aims for continual improvement by companies in the areas of environment, safety, and health, regardless of the legal requirements. We also participate in the further development of scientific risk assessments through our involvement in associations and initiatives. International associations such as the European Chemical Industry Council (CEFIC) and ICCA are working to improve the scientific assessment of chemicals and research new testing methods. Moreover, they monitor implementation of legal regulations. Covestro is actively involved in industry association activities. Furthermore, we endorse the initiatives of the World Health Organization (WHO) and the European Union (EU) to improve health and the environment, for example with the further development of human biomonitoring through an alliance with the German Chemical Industry Association (Verband der Chemischen Industrie, VCI) and the German Federal Ministry of the Environment.

Implementation of regulations and voluntary programs pertaining to chemicals

Covestro adheres to the applicable regulations pertaining to chemicals, such as REACH in Europe and the Toxic Substances Control Act (TSCA) in the United States. These regulations are aimed at protecting human health and the environment from the risks posed by chemicals, and thus shape our activities as a manufacturer, importer, and user of chemicals. We have established internal regulations to adequately address the range and complexity of the relevant requirements. They guide our employees in fulfilling regulatory requirements.

Substances registered according to REACH are assessed by regulators. This can result, for example, in additional testing requirements, new risk management measures, or inclusion in the REACH authorization or restriction procedure. A number of Covestro substances are also affected by this procedure, which restricts the use of particularly hazardous substances or can lead to their substitution or prohibition. The restriction on diisocyanates published in the Official Journal of the European Union in August 2020 is one example of a restriction. In this case, labeling of diisocyanates must be modified by February 2022, but this will not affect their availability. However, all users of products containing diisocyanates at a concentration of more than 0.1% of the residual monomer must be trained in their use by August 2023. Covestro supports this process and advocates for the practical and effective implementation of this requirement, for instance in the preparation of training materials. As a member of the European chemical industry, we made a voluntary commitment to review and improve the REACH registration dossiers by the year 2026.

In addition, Covestro pursues the goal of completing the assessment of the hazard potential for all substances used around the world in quantities exceeding one metric ton per annum by the end of 2020. This goal was more than 99% achieved in the reporting year. We thus exceed statutory requirements. In addition, we ensure that substance assessments comparable to those meeting the high standards of REACH or the TSCA will also be applied at Covestro sites that are not subject to these regulations. The relevant procedure is established in the corporate regulation on “Product Stewardship” in the attachment entitled “Substance Information and its Availability.” When it comes to purchased substances, we are dependent on information provided by our suppliers.

Another example of our commitment to Responsible Care™ is the worldwide support we provide for customers for safely handling large quantities of reactive products through tank-farm safety assessments.

Covestro has also committed to compliance with animal welfare policies during toxicological and ecotoxicological testing.

We support the Global Product Strategy (GPS), a voluntary commitment by the chemical industry initiated by the ICCA. Its objective is to improve knowledge about chemical products, especially in emerging and developing countries, and thus increase safety in the handling of these products. GPS is accessible at Covestro through the Product Safety First internet portal and is available worldwide. On this website, we inform our customers and other interest groups about safety-relevant properties and the safe handling of our products.

Substances that are the subject of public debate

Covestro is following the scientific discussion about the chemical bisphenol A (BPA), an important raw material for various plastics. Critics, but also some authorities, are concerned that risks could result for users and the environment if traces of BPA are released from products. At this time, these concerns are primarily being discussed in the context of the European chemical regulation REACH.

Based on numerous scientifically valid and high-quality studies, Covestro is confident that BPA can be safely used in all areas of application supported to date. This assessment is underscored in the case of food safety, for instance, by the latest evaluations from the responsible European and American authorities, namely the European Food Safety Authority (EFSA) and the US Food and Drug Administration (FDA). By participating in regulatory processes, Covestro works actively to dispel uncertainties and answer open questions. In addition, we continue to advocate for more objective discussions based on all of the scientific data in cooperation with the PlasticsEurope association, the American Chemistry Council (ACC), and the China Petroleum and Chemical Industry Federation (CPCIF). Covestro is involved in the discussions and provides information to customers and the public on this issue through associations, on the Covestro website, and through direct contacts.