Environmental Compliance

We are proud of our long history of strong environmental compliance at all levels and locations of our company. Our environmental programs are built upon our core values of ethics and integrity embedded in our key company policies: the Code of Business Conduct and Ethics and the global Safety, Environment, Energy, Quality (SEEQ) Policy.

Our Approach

Each year, our CEO reviews and updates our SEEQ Policy from which flow our global environmental standards memorialized in various global policies and guidelines applicable to all locations. However, the heart of environmental compliance rests on our operational leaders, plant managers and local teams of environmental professionals, who are responsible for setting detailed workflows and implementing global and local compliance management actions at each operating location. We closely track key performance indicators (including leading indicators) to head off potential incidents and to provide the information we need to continuously improve.

ISO 14001 & Responsible Care

To support our compliance programs, each titanium dioxide operating facility maintains a site-specific environmental management system aligned with ISO 14001:2015 and/or Responsible Care. These systems address each facility’s need to maintain compliance with local laws and regulations.

Our four European operating facilities hold ISO 14001:2015 certifications, while our Canadian facility is certified to the Responsible Care standard. Additionally, some of our European facilities are also subject to the SEVESO III Directive, providing an additional layer of regulatory requirements related to environmental protection and worker and process safety.

These systems utilize internal and external audit processes that conform to the ISO 14001:2015 or Responsible Care standard and ensure adherence to KRONOS guidelines, applicable local and national laws, and SEVESO standards. We have also implemented rigorous procedures for incident reporting and investigation, including root cause analysis of environmental and safety incidents and near misses, identifying appropriate corrective actions to prevent reoccurrence.

Facility Certification and Registrations

Loss of Primary Containment Tracking – a Leading Indicator for Compliance

In 2018 KRONOS implemented a new key performance indicator – Loss of Primary Containment – intended to identify and quantify unintentional releases from manufacturing process equipment and piping that do not trigger regulatory reporting or notification. An LoPC is defined as an unplanned or uncontrolled release of material from within its primary containment. LoPCs do not require reporting to local authorities because they remain contained in secondary containment systems or otherwise do not impact the environment. However, in the event a release requires regulatory notification, it becomes an Environmental Incident. In this way, the rate of occurrence of LoPCs serves as a leading indicator to prevent Environmental Incidents. We have made good progress on reducing the number of LoPCs and thus Environmental Incidents since the inception of this program.

LoPC is an internal benchmark we use to identify progress and opportunities for improvement. This metric is not intended to be directly comparable to similar metrics utilized by other companies to track environmental performance.

Environmental Incident Tracking

KRONOS tracks environmental incidents of all magnitudes, including minor deviations. In the event a release or other incident meets or exceeds a local regulatory reporting requirement, we track it as an Environmental Incident. Notification is provided to the local authorities and an internal root cause analysis takes place followed by appropriate corrective action measures designed to prevent recurrence.

Our goal is zero incidents. In 2018 we implemented the new LoPC leading performance indicator, which allows us to identify potential conditions that could lead to an incident. Since then, through root cause analysis and proactive actions, we have seen a dramatic decrease in the number of reportable incidents.

Environmental Incident tracking is an internal benchmark we use to identify progress and opportunities for improvement. This metric is not intended to be directly comparable to similar metrics utilized by other companies to track environmental performance.