Responsible Care®
Management Systems Verification

Prepared by
Verrico Associates
August 19, 1999

Responsible Care® is a registered service mark of the Chemical Manufacturers Association

Executive Summary

A Responsible Care Management Systems Verification was conducted at the Roche Colorado Boulder plant on July 27, 1999.

A verification team made up of industry representatives, public participants, and management systems verification consultants evaluated Roche Colorado Corporation's Safety, Health, and Environmental management systems using the Chemical Manufacturers Association's protocol.

The verification focused on processes for implementing Responsible Care and an evaluation of the management systems necessary to ensure the sustainability and continuous improvement of safety, health, and environmental performance. The verifiers evaluated employees' understanding of Responsible Care and of safety, health, and environmental processes. The team looked for systems that establish and meet appropriate levels of performance; provide for outreach to all stakeholders; assign responsibilities, authorities, and accountabilities; are documented, and provide for adequate resources to implement Responsible Care.

The team found a number of strengths at Roche Colorado relative to safety, health, and environmental management systems.

F. Hoffmann-La Roche is committed to the implementation of Responsible Care on a worldwide basis.
There is a cross-functional compliance team to address a variety of internal and external SH&E requirements.
Roche Colorado has a comprehensive incident database that includes all types of incidents including SH&E and quality.
Roche Colorado applies Process Safety Management (PSM) to all operations regardless of regulatory requirements.
Roche Colorado has a comprehensive SH&E audit process including a Corporate Safety and Environmental Affairs (CSEA) audit and site-based audits.
There is a process for initial CSEA audits for waste disposal contractors.
Roche Colorado has systems for providing their product carriers with appropriate risk information, including providing drivers with an MSDS for every load.
There has been a significant cultural change at Roche Colorado with regard to the reporting of incidents. Roche Colorado management has communicated the benefits and value of reporting to employees.
There is a comprehensive process for the ongoing review of legislative and regulatory issues by both the Roche corporate group and by Roche Colorado.
There has obviously been a significant improvement in community outreach in recent years. Outreach efforts include employee participation in community projects, school science show, annual pollution prevention reports to the City of Boulder, work with the City of Boulder, and the community advisory panel (CAP).
The team concluded that several items could be considered industry examples of Responsible Care excellence evident at Roche Colorado.
Roche Colorado's performance review for all employees is an example of Responsible Care excellence. Performance includes SH&E metrics and can impact compensation.
The Roche Colorado Process Manual, used to document hazards and procedures for each process, is an example of Responsible Care excellence.
Roche Colorado's comprehensive and documented training systems are an example of Responsible Care excellence.
Roche Colorado's contractor qualification and selection process and the process to continually monitor contractor safety are an example of Responsible Care excellence.
The independent operation of the Roche Colorado CAP is an example of Responsible Care excellence. In the spirit of continuous improvement, the team concluded that there are a number of opportunities for Roche Colorado.
There is an opportunity to formalize and document the Roche Colorado transportation emergency response process.
There is an opportunity to formally define the response procedures to community recovery needs in the Roche Colorado emergency response plan.
There is an opportunity to formalize the process for the qualification of suppliers to include SH&E performance.
Although Roche Colorado has developed a questionnaire for the qualification and selection of carriers, there is an opportunity to formalize the process for the selection of carriers.
In the spirit of Responsible Care, there is an opportunity for Roche Colorado to formalize a process to routinely evaluate their contract manufacturing customer's product stewardship programs.
There is an opportunity to continue the development of a company web site for community and stakeholder access to SH&E information.

Roche Colorado
Responsible Care
Management Systems Verification

Introduction
A Responsible Care Management Systems Verification was conducted at the Roche Colorado Boulder plant on July 27, 1999.

A verification team made up of industry representatives, public participants, and management systems verification consultants evaluated Roche Colorado's Safety, Health, and Environmental management systems using the Chemical Manufacturers Association's protocol.

This evaluation was based on interviews with individuals with functional responsibilities related to Responsible Care.

Industry Verifiers:
Rick Turner Director of Regulatory Affairs and Responsible Care coordinator for LaRoche Industries

Ed Gunderson Director of Regulatory Affairs and Responsible Care coordinator for Stepan Company

Community Verifiers:
Brian Athearn Citizen of Boulder, Member of Roche Colorado CAP

Leonard Lewin Citizen of Boulder, Member of Roche Colorado CAP

Lee Shepard Citizen of Boulder, Member of Roche Colorado CAP

CMA Facilitators:
Don Verrico Verrico Associates

Mary Verrico Verrico Associates

Format

An open-ended question format was used. The questions focused on processes and were designed to evaluate the development, integration, and effectiveness of management systems necessary to ensure the sustainability of Responsible Care. The verifiers looked for understanding of safety, health, and environmental systems to establish and meet appropriate levels of performance, documentation, and the adequacy of resources.

This report details the verification team's methodologies, observations and findings as follows:

There are several sections detailing the process and the management systems concept. The protocol used for this verification was crafted to follow the ISO 14001 Environmental Management System specification document. The five management systems are described in some detail along with the system attributes.
There is a Findings and Recommendations section where the company's strengths and opportunities for improvement are discussed. This is the evaluative section of the report.
Appendix A contains feedback the verification team received during its interactions with commercial partners, Roche Colorado employees, and community participants.
This report reflects a consensus of the management systems verification team's findings for this company. The facilitator used the comments, daily wrap-up reports, and notes from all team members to create this report. The industry members of the verification team have reviewed it to verify that it reflects their observations and conclusions.

Verification Methodology

The structure of the protocol is designed to evaluate five Management Systems that can apply to all of the Responsible Care Codes. Attributes were created to reflect common threads and finally open-ended Questions, which reflect these attributes, were developed. While this process is not designed to determine the implementation of the 106 Management Practices that make up Responsible Care, each of the Codes was considered in the development of the protocol.

The five Management Systems are:

Policy and Leadership
Planning
Implementation, Operation and Accountability
Performance Measurement and Corrective Action
Management Review and Reporting

The Attributes are based on analysis of the Responsible Care Management Practices and describe the necessary systems, organization, and policies for a group of management practices. These attributes make up the backbone of each management system and are the basis for the evaluation of each system.

The Questions were derived from the attributes and the Responsible Care Codes of Management Practices. They are open-ended and intended to evoke discussion, demonstration, example, etc. "Yes-No" or "Check-List" types of questions were avoided.

Process

The facilitator coordinated activities with Roche Colorado several months before the actual verification. The company was provided with a copy of the protocol. Gary Matthews, the Corporate EH&S Director was the primary contact and coordinated this process for the company. He arranged all logistics and schedules and worked to identify and prepare appropriate interviewees.

The verification questions were sorted by interviewee and panels were scheduled by combining several functional areas. The site visit included a plant tour, telephone calls to select commercial partners, and random employee interviews.

Findings and Recommendations

1. Policy and Leadership

Senior management at Roche Colorado is visible to the organization and demonstrates that they place a priority on Responsible Care and on safety, health, and environmental issues. There are policies, goals, and guidelines for safety, health, and environmental performance and a demonstrated value for the Responsible Care ethic.

Management Commitment
Management at Roche Colorado is committed to Responsible Care and safety, health, and environmental (SH&E) programs.

The President and Site Manager hosts quarterly meetings with employees which include discussion of SH&E issues and routinely meets with the community to assess concerns and emphasize SH&E issues. He has a policy of continuous improvement, setting goals and objectives, and listening to the community and to employees.

There is a Roche Holdings Ltd Corporate SH&E group that is represented on the corporate executive committee.

Roche Colorado has created a cross-functional compliance team to address a variety of internal and external SH&E requirements.

The company acknowledges that they have responded to community concerns and improved their community outreach policies and practices. A community participant in the MSV process commented that Roche Colorado is "anxious to learn." This is also evident by their volunteering for the Responsible Care MSV.

Relevancy of Policies
At Roche Colorado, public concerns effect company behavior. Roche Colorado management acknowledges that they operate with a sensitivity to the concerns of their community.

The corporation has a Policy on safety and environmental protection, the US Group has set general guidelines, and Roche Colorado has developed a site-specific policy that is relevant to the nature of their operations.

Goals and Objectives
The company and site have established SH&E and Responsible Care goals. Roche Colorado refers to this as a "top down and bottom up approach." The Roche Corporation has set broad corporate goals including continuous improvement and emissions reduction. In addition Roche Colorado employees can also identify issues that can be addressed as annual goals and objectives. Corporate goals lead to individual goals, which are established annually at "off-site" sessions. Corporate numeric goals are translated to activity goals for plant employees. New goals are set based on areas of weak performance.

Communications
Roche Colorado has an aggressive program for communicating with stakeholders, including employees and the community. Outreach has become a priority for Roche Colorado management.

The corporation produces an annual SH&E report with specific reference to Responsible Care. This report includes management's commitment to the spirit of Responsible Care.

Community outreach at Roche Colorado includes a community advisory panel, regular press releases, community meetings, and meetings with the City of Boulder officials. Roche Colorado is involved in a number of external groups where there is an opportunity to communicate SH&E activities, including the Boulder County Clean Air Consortium, the local Environmental Information Consortium, the CMA, and the pharmaceutical industry sponsored PhRMA Safety Group. There has obviously been a significant improvement in community outreach in recent years. As an example, in response to the community's concern about the Y2K issue, the company has decided to shut down on New Year's Eve.

The Roche Colorado Community Advisory Panel has been empowered to provide the company with information relative to community concerns. The CAP is independent with their own executive committee. They serve as a conduit to the community. Their selection of new members is through a credible process of advertising in the newspaper. This is done by the CAP not by Roche Colorado. The CAP has also sponsored an "activist forum" to solicit concerns about Roche Colorado. The independent operation of the Roche Colorado CAP is an example of Responsible Care excellence.

There is an opportunity to continue the development of a company web site for community and stakeholder access to SH&E information.

There are a number of internal communications mechanisms for employees regarding health, safety, and environmental issues and performance that are referenced in other areas of this report. In addition, the site compliance team meets with employees on a monthly basis to review performance statistics and programs.

Employee Involvement and Awareness
Roche Colorado employees are involved in site safety, health, and environmental and Responsible Care programs. Employees are involved in a number of site issues, including environmental issues and incident investigations. These activities involve hourly employees in SH&E issues. There is a "satellite safety committee" that includes hourly employees. Interviewed employees demonstrated an awareness of Roche Colorado's emergency procedures.

Employees are encouraged to speak to community groups and to provide Roche Colorado with community feedback.

Interviewed employees demonstrated an awareness of Responsible Care programs and SH&E policies. Employees communicated that they were empowered to make decisions if they felt that community or employee safety could be impacted.

2. Planning

Roche Colorado has processes to address the identification and assessment of relevant legislation, regulations and industry standards, to determine the adequacy of resources for safety, health, and environmental program implementation, to evaluate product, process and distribution risks, and to identify and assess employee and community concerns about the organization's safety, health, and environmental performance.

Assessment of Hazards and Risks
Roche Colorado has systems to assess risk for its products and processes and for the transport of its products.

Product Risk
The FDA regulates most of Roche Colorado products and product risk reviews. Roche Colorado also functions as a contract manufacturer for two large companies. They have recently sent letters to these companies asking them questions relative to product risk assessment processes. In the spirit of Responsible Care, there is an opportunity for Roche Colorado to formalize a process to routinely evaluate their contract manufacturing customer's product stewardship programs.

Roche Colorado does an annual review of MSDSs for their products and provides this information to customers.

Process Risk
The company uses a risk review team to assess risk for new processes. Risk review teams involve management, engineering, and hourly employees. Roche Colorado uses Process Hazard Analysis techniques to assess new process risks. Before the pilot plant phase there is an initial conceptual review of the process that includes safety, industrial hygiene, and environmental issues. Multiple approvals are required. When the project moves out of the pilot plant to production, a technology transfer package is prepared and a process hazard analysis (PHA) is performed.

Roche Colorado routinely reviews its existing processes to assess risk. The company applies PSM to all operations regardless of regulatory requirements.

For changes to existing process, Roche Colorado has a documented Management of Change (MOC) system. This system applies to all process changes except replacement-in-kind.

Distribution and Transportation Risk
Roche Colorado assesses transportation risk for its products. This risk assessment involves a review of chemical hazards, packaging, and routing. Routing risk assessment includes considerations of population centers, schools, and hospitals. Local shipping routes are defined by the City of Boulder and these are communicated by Roche Colorado to its shippers.

Objectives and Targets
The company has integrated Responsible Care goals with its business objectives. There is a continuous improvement philosophy for health, safety, and environmental performance.

There are quantifiable goals for SH&E throughout the company. These goals start at the corporate level, are integrated in plant practices and cascade down to individual employees.

Regulatory Information
There is a comprehensive process for the ongoing review of legislative and regulatory issues by both Roche corporate group in New Jersey and by Roche Colorado. Corporate and plant SH&E professionals keep the company informed about regulatory information, and provide interpretations to the relevant businesses and plant sites. Safety, health, and environmental staff receive information through trade association participation and regulatory contacts.

The Roche Colorado compliance team has the responsibility for assuring that regulatory information is communicated throughout the organization and that implementation plans are in place.

Resource Allocation
Roche Colorado management makes resources available for safety, health, and environmental implementation. While Roche Colorado has a dedicated staff of SH&E professionals for these activities, line management is responsible the implementation of Responsible Care programs and for performance. If additional resources are needed, there is a requisition process for additional staffing.

Hourly production employees are involved in safety, health, and environmental activities. The Safety Committee at the site includes management and hourly employees.

Assessment of Community and Employee Concerns
Roche Colorado conducts routine employee surveys, utilizing the CMA annual survey to assess concerns and to measure the effectiveness of their communications.

The company has done a community survey involving the CAP and currently the CAP is working on a new survey to assess community concerns. The CAP has also conducted an "activist forum" to assess activists' concerns about Roche Colorado.

3. Implementation, Operation & Accountability

Roche Colorado has systems in place to achieve goals and objectives in support of its safety, health, and environmental policy. Management systems also address the preparation and competency of employees and documentation that is critical to safety, health, and environmental performance.

Responsibility and Accountability
The philosophy at Roche Colorado is that line managers are accountable for SH&E performance. There are Responsible Care Code managers who are primarily SH&E professionals but in some cases, depending on the Code, are part of the line organization.

Training Programs
There are systems to train Roche Colorado employees for job skills, EH&S issues, and Responsible Care awareness. Training programs also pertain to emergency response and regulatory requirements.

Employee developmental training progress and needs are documented and training levels are tracked through a database.

Roche Colorado's comprehensive and documented training systems are an example of Responsible Care excellence.

Employee Involvement
There are systems at Roche Colorado to involve employees in Responsible Care and SH&E programs and processes. Employees are included in Roche Colorado's Satellite Safety Committees. Hourly employees participate in Satellite Safety Committee leadership positions. Through this involvement, Roche Colorado employees have opportunities to voice concerns directly to management. Employees are also encouraged to be involved in the community. They participate in science demonstrations at local schools. There is an opportunity to benchmark with other companies through CMA to establish more formal employee "ambassador" programs.

Operating Procedures
Roche Colorado's manufacturing processes are documented and maintained in a computerized database. Plant operators have access to this database.

Roche Colorado maintains separate process manuals for operating procedures. The manuals outline safety, health, and environmental issues relevant to the procedure.

Operations and maintenance employees annually review the company's operating procedures.

The Roche Colorado Process Manual, used to document hazards and procedures for each process, is an example of Responsible Care excellence.

Emergency Response Plans
Roche Colorado has emergency response plans that include provisions for the empowerment of employees during an emergency and involve considerations for accountability of site employees, contractors, and visitors.

There is routine training of the site's emergency response plan that includes the site emergency response team and local emergency responders.

Roche Colorado is well integrated with the area emergency response organizations. They are members of the LEPC and involved in community emergency preparedness.

There is an opportunity to formally include community recovery needs in the Roche Colorado emergency response plan.

Transportation Emergency Response
In the event of an off-site incident involving a Roche Colorado product, the company provides technical data, such as MSDSs, to on-site emergency responders. Although Roche Colorado does not typically respond to an off-site event, the company will provide a qualified emergency response contractor if necessary.

While there are practices in place to respond to transportation incidents, there is an opportunity to formalize and document the Roche Colorado transportation emergency response process.

Commercial Partners

Carriers:
For Roche Colorado's external business, customers select carriers. Roche Colorado is a considered a contract manufacturer for these customers, and products are shipped on behalf of the customer. Roche Colorado periodically reviews the customer's carrier selection and qualification, training, and route selection to assure that the carriers are meeting the spirit of Responsible Care.

Although Roche Colorado has developed a questionnaire for the qualification and selection of carriers, there is an opportunity to formalize the process for the selection of carriers.

Carrier incidents are included in Roche Colorado's incident tracking database.

Contractors:
There is a system in place to qualify and select site contractors that includes a review of the contractor's safety, health, and environmental performance and programs. Performance information includes evaluations of Total Recordable Injury Rates (TRIR) and Experience Modification Rates (EMR). Safety, health, and environmental programs include reviews of training information, emergency action plans, personal protective equipment (PPE), incident investigation procedures, and vehicle safety.

There is a site orientation that contractors must complete before they begin work at Roche Colorado. The orientation includes the site's safety requirements as well as the site's chemical and process hazards. A badge system is used to verify that contractor employees have completed the orientation process.

Roche Colorado's contractor qualification and selection process and the process to continually monitor contractor safety are an example of Responsible Care excellence.

Customers:
Roche Colorado does not have direct customers. For two of their products, they are contract manufacturers for other companies. Roche Colorado has recently requested information from these companies relative to their product stewardship practices with their ultimate customers. They transfer their other products to other Roche facilities.

In the spirit of Responsible Care, there is an opportunity for Roche Colorado to formalize a process to routinely evaluate their contract manufacturing customer's product stewardship programs.

Suppliers:
While supplier companies are usually CMA member companies and practice Responsible Care, there is an opportunity to formalize the process for the qualification of suppliers and include a review of safety, health, and environmental performance.

Roche Colorado requires MSDSs from their suppliers of raw materials.

Waste Disposal Contractors:

Roche's US corporate group has a waste vendor audit protocol to select and qualify waste disposal contractors. This qualification includes evaluations of waste disposal contractors' safety, health, and environmental performance.

Emissions:
Reduction and Groundwater Protection Programs
Roche Colorado participates in statewide and local emissions reduction and groundwater protection programs. The company has internal pollution prevention teams that identify waste and emission reduction opportunities, track progress, and define short and long term pollution prevention goals.

4. Performance Measurement and Corrective Action

Roche Colorado has systems in place to assess the need for change and appropriately modify its operations and activities. There are systems to measure and review safety, health, and environmental performance, investigate accidents and incidents, audit compliance, and record data. There is also a process for taking corrective actions and assuring that there is appropriate follow-up.

Tracking and Investigation of Emissions, Releases, Accidents, and Incidents
Roche Colorado has established a comprehensive incident reporting process. Incidents are defined as "any unplanned or undesirable" events. An SOP has been developed for incident investigation and any employee can generate an incident report.

The incident database is used to track all incidents, including SH&E, process safety, transportation, and quality incidents. It also includes near misses. Reports are generated on a weekly, monthly, and quarterly basis. This database also is used to establish incident trends, which are done on a monthly and annual basis. Key figures are reported to corporate headquarters on an annual basis. There is also an industrial hygiene database.

There has been a significant cultural change with regard to the reporting of incidents. Roche Colorado management has communicated the benefits and value of reporting to employees.

Reviewing Performance of Commercial Partners

Carriers:
Although most carriers are selected by Roche Colorado's customers, there is an opportunity to formally evaluate carrier performance and review it with the carrier companies.

Contractors:
Roche Colorado conducts routine contractor safety audits. The results of these audits can be to remove a contractor from the company's approved contractor list.

Roche Colorado also conducts spot "gate audits" as the contractors come in to the facility to test their safety knowledge.

Customers:
Because Roche Colorado does not have direct customers for their products, there is no formal system in place for tracking customer safety, health, and environmental performance.

Suppliers:

Roche Colorado uses an incident database to track and review supplier incidents. This can include safety or environmental incidents.

Waste Disposal Contractors:
Roche Colorado conducts annual reviews of waste disposal facilities to track safety, health, and environmental performance.

Roche's corporate group re-audits waste disposal contractors for safety, health, and environmental performance every three years.

Audit of Compliance
There is a comprehensive system of internal audit and review for Roche Colorado, products, and processes. There are corporate audits performed by the Corporate Safety and Environmental Affairs (CSEA) group and internal plant audit systems in place. CSEA conducts comprehensive audits every three years or more frequently if necessary.

The plant, under the Compliance team, performs self-audits of safety, health, and environmental practices on a regular basis. There is an SOP for internal audits and a schedule to assure that all areas are audited on an annual basis. An audit report is generated and reviewed with the line manager. Corrective actions are identified and a timeframe for them is established.

Measuring Effectiveness of Communications
Roche Colorado uses both formal and informal mechanisms to measure the effectiveness of communication with employees and the community.

Employee communications are assessed using the annual CMA survey and informally using feedback from employee meetings. Roche Colorado also participated in a Roche worldwide Responsible Care implementation survey. Feedback gained from these assessments is used to develop employee communications strategies.

There has been a formal community survey and there are a number of informal mechanisms to measure the effectiveness of external communications. The community was surveyed in 1995 (through the CAP) to solicit concerns. Currently, the CAP is working on the development of another survey.

5. Management Review and Reporting

Roche Colorado has mechanisms to report its safety, health, and environmental performance to its stakeholders. There are periodic reviews of performance and changes are made to goals, policies, and priorities. The corporate system provides for an annual review of objectives. There is dialogue relative to this review between corporate and site management.

Periodic Review of Objectives and Policies
Initiatives are identified for each Responsible Care Code and these are reviewed annually. There are also pollution prevention goals that the company has established that are reviewed with the City of Boulder on an annual basis. The cross-functional compliance team reviews objectives and policies on a regular basis.

Reporting Mechanism to Stakeholders
Roche Colorado prepares and distributes a community annual report that details a wide variety of SH&E performance indicators. This is routinely reviewed with the CAP.

On a quarterly basis Roche Colorado management reviews SH&E performance with employees and routinely posts performance data.

Benchmarking
Roche Colorado does extensive internal benchmarking with other Roche facilities. The company has established a North American Responsible Care network of Roche facilities. There are corporate international Responsible Care meetings to share best practices for Responsible Care implementation.

Externally, Roche Colorado benchmarks Responsible Care programs through involvement with CMA. The company compares its performance data to the industry leaders. Roche Colorado also uses consultants to benchmark performance.

Performance Management System for Employees
Roche Colorado has an employee performance review process. Employees have SH&E as part of their job responsibility. The annual strategic site goals are 'cascaded' down to individual employee objectives. These objectives become part of the employee's performance evaluation on a semi-annual basis. Performance, that includes SH&E metrics, can impact compensation. There are quarterly employee recognition dinners that includes awards for SH&E performance.

Roche Colorado's process to conduct employee performance reviews for all employees is an example of Responsible Care excellence.

APPENDIX A

Comments from Third Parties, Commercial Partners, and the Verification Team

From Community Participants:
"Roche employees, including plant employees, are anxious to learn."

"Roche is committed to implementing Responsible Care codes and making them interdisciplinary. Many people are responsible for this and all segments of the plant are working together. They are working to make things better."

"I am impressed with the quality of all the employees."

"The MSV process helped me understand Roche."

"I was very impressed with what I saw. All of the employees knew that they were personally responsible."

"I was impressed with the employees' concern for safety."

" All employees knew their area and gave good answers to tough questions."

"Roche people can be proud of what they have."

"People are open and answered our questions."

From Industry Verifiers:
"Lots of thought and time were put into developing your dynamic programs."

"You need to be very proud of what you are doing here. You have changed your attitude towards the community. You are doing the right thing."

From Employees:
"There is only one of me and only one of you and we are both important. Safety is first."

"If there was a problem in the plant the first thing I would do is get you out of here."

"If we do not report an accident or try to cover up then we are out the gate."

"I am proud to work here and my family is proud also."

"I've worked in lots of other plants but by far this one is the cleanest."

"Everyone here is responsible for safety."

"Roche has procedures for everything."

From Commercial Partners:

Carriers:
"We get hazardous training every two years and we use compatibility charts."

"Roche provides videos and safety training for our drivers."

"Roche provides EHS information through MSDSs."

"Roche tracks our safety performance."

Waste Disposal Contractors:
"Roche audited our facility."

"We get risk information from the manifest profile and from MSDSs. Roche is very good about identifying their products."

"Roche provides videos and training materials."

"Drivers are trained in the proper segregation of wastes."

"Roche is very good to work with and their training materials are very good."

Contractors:
"This is one of the best places to work in the area and I work all over."

Customers:
"We audit Roche every two years. They have an outstanding Responsible Care program so we don't audit them more frequently."

"Roche is one of the best companies that we deal with. We are impressed with their facilities and the knowledge of their people."

Suppliers:
"Roche sets up plant visits for us to provide them with information on safe handling."

"Roche is very interested in safety. They require training for all drivers who go into their plant."

"Boulder has unusual environmental requirements and Roche follows them."

"Roche put in a first class system to store our product. We are struggling to get ours as good."

Roche Colorado Responsible Care® Management Systems Verification
Findings and Recommendations

Roche Colorado
8/19/99

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Responsible Care® Management Systems Verification

Roche Colorado Responsible Care Management Systems Verification