As we approach the end of 2024, it is a perfect time to take stock of accomplishments and reflect on what has transpired over the last year. This allows companies to identify and complete any outstanding items, as well as set goals for the new year ahead. Responsible Distribution is a program built on a foundation of continuous improvement. Taking the time to review these key areas each year will help drive improvements in the new year. While formal Responsible Distribution verifications occur in three-year intervals, many aspects of Responsible Distribution need to be addressed on an annual basis. Below are some helpful suggestions for a Responsible Distribution end-of-year checklist:
• Internal Audits – Code X (Internal Audits) routinely ranks as one of the highest non-conforming Codes. This is due to companies not completing Responsible Distribution Internal Audits as outlined by the Code X requirements.
o Did you complete your 2024 Responsible Distribution Internal Audits?
o Were audits conducted at all locations, including third-party warehouses?
o Were the results reviewed with and signed off by Senior Management?
• Training – Several Codes cover various aspects of employee training (Codes I, II, V, VII). Confirming that all training is up to date helps ensure the safety and competency of employees.
o Review the company training matrix/records. Are there any missed, incomplete, or outdated training requirements?
o If your first Responsible Distribution verification is coming up in 2023, have you completed the required ACD U Responsible Distribution courses?
o Were there any changes to policies or procedures in the last year that required additional training?
• Annual Drills – Code VII (Emergency Response and Public Preparedness) requires the annual review and testing of the company’s emergency response plans. Depending on the scope of your operations, the level of review and testing may vary.
o Did you complete and document a fire/evacuation drill in 2024?
o Did you review your emergency response plans for accuracy or test any additional emergency scenarios?
• Engagement/Invitations – Codes VI (Sustainability) and VII (Emergency Response and Public Preparedness) both have requirements around community engagement and advocacy. The end of the year is the perfect time to take stock of community outreach and advocacy efforts, especially as local outreach activities may increase during the holiday season.
o Did you invite your local emergency responders to tour your facility?
o Have you attended a Local Emergency Planning Commission (LEPC) meeting?
o Did you document any community outreach, service, or charitable activities?
o What advocacy efforts were performed this year? Did you submit comments on any rulemaking, participate in ACD’s Washington Fly-In, or host a site visit with policymakers?
• Corrective and Preventive Actions (CAPAs) – Having an effective CAPA system (Code XI) allows companies to track and review actual and potential non-conformance issues. The end of the year provides a great opportunity to review your CAPA log.
o Did you use your CAPA log effectively to document and track all actual as well as potential non-conformance? A best practice is to take lessons learned from Code VII emergency response drills or near misses and add them to your CAPA log.
o Are there any outstanding CAPA records?
o If any records are outstanding, why? Were follow-ups conducted at identified intervals (60 or 90 days)?
o Did you verify the effectiveness of actions taken to ensure that the changes implemented are working?
This December, remember to check your Responsible Distribution list twice to help avoid some of the common pitfalls associated with maintaining a successful program. This end of year activity will also help set your program up for success going into the new year. Don’t forget, ASK Distribution Consulting, LLC has many resources to help companies prepare for verification and continuously improve their Responsible Distribution programs.
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