Frequently Asked Questions
Here the CAP has paraphrased some frequently expressed concerns along with brief responses that may become a starting point for future discussion. These questions do not necessarily reflect the concerns of the community as a whole, and the answers do not represent the official position of Corden Pharma Colorado Corporation (CPC).
--------------------------------------------------------------------Does the CAP have any actual authority or means of sending formal recommendations to the company?
The CAP has no actual authority over the company but we do make formal recommendations that we believe are taken seriously. Examples: In 1993, the CAP recommended an audit of the company's compliance with the CMA Community Awareness and Emergency Response (CAER) code. This audit was carried out. In 1995, the CAP recommended that the company set up a World Wide Web site as a community interface. In 1996, the CAP recommended substantial changes to the Responsible Care Progress Report and to the Environmental Control System Fact Sheet. In 2002, the CAP held numerous lengthy discussions focused on the necessity of retesting the company ECS (emissions control system) with the change to Fuzeon manufacture. This led to an CPC decision to install a second ECS and to retest the original ECS as well.-----------------------------------------------------------------------
Where can I find detailed information about company environmental and safety reports?
The EPA Enforcement and Compliance History Online has information about enforcement history by company, by quarter: http://www.epa-echo.gov/echo.The Toxic Release Inventory (TRI) is an EPA database with information about toxic chemical releases and waste management plans: www.epa.gov/tri.
OSHA inspection and enforcement actions reported by company may be found here: http://www.osha.gov/pls/imis/establishment.html.
Corden Pharma Colorado has always made all of its emissions data public. Go to the Corden Pharma Colorado Website link in the Table of Contents at the left side of this page and look under Pollution Prevention Reports for details. Other links from Corden Pharma Colorado Website page lead to sites for local business environmental programs that CPC participates in.
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Is TRI (EPA Toxic Release Inventory) data reliable when it is provided by the company that is doing the polluting?
Like most environmental data, TRI data is reported to the EPA by companies and is subject to government audits. Most violations are identified from this self-reporting. Failure of companies to accurately report data is subject to enforcement actions that occur most frequently with companies that fail to recognize that they meet the criteria requiring them to report.TRI data is most useful to compare a company's progress from year to year, to compare companies within an industry group, or to compare different industries.
------------------------------------------------------------------------Would it be possible to have a public presentation specifically addressing how emission reductions are achieved at the CPC plant?
This certainly is possible. The CAP has within its guidelines the option of holding meetings in which the public is welcome. We would like to be able to meet with other public interest groups such as neighborhood associations but response to these proposals has not been forthcoming from the general public. In the meantime, CAP members try to stay tuned to community concerns as they associate with their friends, neighbors and other groups within the community.
------------------------------------------------------------------------Some people seem to feel that you can't trust a big company like Corden Pharma Colorado to behave responsibly, so shouldn't the burden of proof be on the company to convince us that its operations are safe?
The CAP believes that it is important for the public to understand that it's impossible to prove that anything is absolutely safe. (For example, try to prove that your tap water is safe to drink.) The best that you can do is reduce risk to an acceptable level, compared with all the other risks in life. Most people don't understand the quantitative aspects of risk and chemical toxicity, so we have environmental laws to set and regulate chemical emissions. Behaving responsibly means complying with these laws in a way that can be verified.The CAP recognizes that the meaning of "trust" depends on each individual's experiences and expectations. We recommend replacing trust with skeptical inquiry and reliance on verifiable facts.
------------------------------------------------------------------------Isn't the CAP just a PR tool of the company? How can it work if the company is not sincere about listening and responding to community concerns?
All CAP members feel very strongly that CPC is working sincerely to keep a line of communication open to the community at large by supporting CAP as an independent body. We would resign if we felt we were being used as a company PR tool. The CAP is committed to listening to the community's concerns and to recommending courses of action to CPC management, without "taking sides". As long as this process seems to be working, we will keep at it.
--------------------------------------------------------------------------Aren't CAPs just mandated by the American Chemistry Council (ACC), and not a sincere effort?
CAPs are not, in fact, mandated by the ACC. Whatever the company's motivations for setting up a CAP, we can assure you that the CAP members are sincerely dedicated to serving as a community interface. We are all volunteers and would not waste our time if we didn't think we could make a difference.
-----------------------------------------------------------------------CAP members say that they feel most effective as a sounding board, and less effective at changing policy. Is this frustrating?
The CAP puts most of its energy into being a liaison between the community and the company and very little into actually changing company policy. We would like to hear more about what specific company policies you would like to see changed. We would not hesitate to recommend policy changes that seem reasonable to us.
-----------------------------------------------------------------------Do you really think that the objectives of the CAP are being met?
The CAP periodically asks itself the same question. However, it's primarily in forums like this, where we actually interact with people like you, that we learn what we really have to do. We hope that this is just the first step of a continuing dialogue and that you will continue to press us for answers to issues that concern you.
