Navigating RD23 and the 12 Codes of Management Practice

Navigating RD23 and the 12 Codes of Management Practice

  • Jan 16, 2025
  • Caroline Brooks

Last year, we introduced a series of articles in ACD's quarterly Chemicals in Motion magazine to break down each of the Codes of Responsible Distribution – our trusted environment, health, safety, security, and sustainability program.

For over 30 years, it has helped those in the chemical distribution supply chain establish a framework and structure to ensure they operate, handle, move, and transport chemicals in the safest, most responsible way possible. Centered around continuous improvement, it has become the yardstick against which the chemical distribution industry measures performance and safety.

Although Responsible Distribution is now administered by ACD’s wholly owned subsidiary, ASK Distribution Consulting, LLC, the processes and requirements remain the same.

Responsible Distribution is a prerequisite for ACD membership, helping to set our members apart and proving they operate safely and in the best interests of their employees, customers, and communities.

The first three codes featured in recent issues of Chemicals in Motion:

The first of the 12 codes revolves around senior management commitment and getting that all-important buy-in for the program that will trickle down throughout your organization.

Code I, which contains six subsections, establishes the necessary mechanisms to demonstrate your company's commitment to the process, identify improvements, evaluate risks, communicate changes, and keep Responsible Distribution training at the forefront. It’s important to renew your commitment to the program by reviewing and reinforcing the Guiding Principles each year.

Code I tends to see fewer non-conformances compared with other codes, but some companies still struggle with the requirement to complete Responsible Distribution training and putting a formalized management of change program in place.

  • Code II, Compliance Review and Training (featured in the Q3 2024 edition of Chemicals in Motion)

Among the trickier codes in terms of non-conformance, Code II centers around compliance, specifically the continuous improvement cycle of monitoring, implementing, training, and reviewing those compliance requirements.

Every business is different, and our membership is hugely varied in terms of size and services. Companies tend to trip up with Code II by not fully understanding what applies to them and their operations. It’s important to ensure they go through all the proper processes and complete everything that’s required of them.

Regulations are always changing, so there's a constant need to stay up to date with the relevant requirements, be aware of what’s coming down the line, and recognize how these may impact your operations moving forward. Conforming with Code II is an ongoing process.

  • Code III, Carrier Selection and Private Fleet (featured in the Q4 2024 edition of Chemicals in Motion)

Code III has the second lowest number of non-conformances centered around the transportation aspect of chemical distribution. Consisting of only two parts – one aimed at selecting carriers and the other at companies with private fleets, the code requires a thorough evaluation with the checking of safety records, security plans, regulatory compliance, maintenance, and endorsements – as well as an ongoing performance review.

Carriers are effectively an extension of your business, so you must do your due diligence and ensure that when the product is under their control, it's treated the same as if you were handling it yourself.

Complying with RD23 can initially seem a little daunting, but there are plenty of resources available to help members and Affiliates get to grips with the program:

  • The Responsible Distribution 2023 Specifications & Guidance Document lists all the Codes, specification questions, and provides detailed explanations of all the requirements.
  • The ASK website contains a dedicated Explore A Code section with detailed examples of policies and procedures, along with the Responsible Distribution Starter Kit. This paid resource contains 78 essential documents including examples of policies, procedures, templates, and checklists.
  • ACD U launched its new Learning Management System this year, making it even easier to access the various Responsible Distribution courses focused on each Code.
  • ACD's comprehensive Regulatory Resource Guide incorporates useful weblinks and RegClear videos that help explain the myriad regulations impacting the chemical industry and how they apply to your operations. This is particularly relevant for Code II.

If you’d like to find out more or have any questions about Responsible Distribution verification, contact Caroline Brooks for more information at cbrooks@acd-chem.com.  

ASK Distribution Consulting™, LLC is a wholly owned subsidiary of Alliance for Chemical Distribution (ACD). ASK Distribution Consulting™ is organized for the purposes of supporting the commercial viability and sustainability of companies active in chemical, specialty, and essetial ingredients distribution.

ASK Distribution Consulting, LLC's logo is trademark of ACD.