WHY CHEMTURA DOES NOT DESERVE VERIFICATION UNDER *RESPONSIBLE CARE

*Responsible Care is a term used formerly by the CCPA (Cnd. Chemical Producers Assocn.) and now by the CIAC (Chemistry Industry Assocn. of Canada) to describe the ethics of their member companies. It is an ongoing, evolving and extensive process covering many aspects of a chemical companies dealings with the public in general and with the communities they operate within. What I have read about *Responsible Care quite frankly impresses me. The fact that Uniroyal/Crompton/ Chemtura have ever, even after years of trying, achieved verification, disgusts me.

Recently the Chair of CPAC (Chemtura Public Advisory Committee) has sent out requests for feedback from CPAC and I believe SWAT team members regarding Chemtura's attempt at verification. This request for feedback was accompanied by a number of pages of the *Responsible care Commitments. In other words it was to focus the feedback appropriately in regards to *Responsible care. For the moment I will try to ignore all the other reasons to deny them verification and follow the script.

Pg. 35 "the feeling of engagement by stakeholders from their opportunity to provide input and feedback on company decisions and actions...". I have lived in Elmira for over a decade and in Woolwich Township for over two decades. I have been actively involved in groundwater issues in Elmira for twenty-three years both as a formal CPAC member and not. I am a stakeholder. Recently at a public CPAC meeting when Chemtura were asked by me why it took them three years to respond either verbally or in writing to my repeated requests for feedback and clarification surrounding their consultants discovery of possible DNAPL off their site; they actually gave me an answer. Their public recorded answer was that oh CPAC hadn't taken up the issue so they didn't feel they had to respond. Apparently Chemtura feel that they can pick and choose which particular stakeholders to respond to or not. How "engaged" does that make me feel?

Pg. 37 AC130 f. "include a regular process of communication and dialogue with the community and response to questions, concerns, suggestions etc." See above paragraph!

Pg.42 E. "Other Ethic vs. Responsible Care Ethic"
"Other Ethic" is "public is who we think are the public" vs. *RC Ethic is "public are those who affected or think they're affected". Again Chemtura does not get to pick and choose who they prefer to deal with. One example only would be choosing friends and supporters to represent the community on verification teams and should not be Chemtura's choice.

Other Ethic" is "Ignore or fight advocates" vs. *RC Ethic is "Seek advocates' input". Chemtura have actively lobbied Council, CPAC and others to minimize my input. They have actively at Council, through individual Council members and through individual CPAC members lobbied to decrease public participation through Delegations, Public Forum and even the asking of questions (through the Chair) at public CPAC meetings. This is not *Responsible Care behaviour and this company does not and never has deserved to be so recognized.

I repeat that I have stuck to just a few pages of the CIAC's own Code and Ethics. There are literally a hundred other examples of reprehensible behaviour towards the community by this company over the last twenty-three years. A most recent example is their false and inaccurate personal attack upon the CPAC Chair at a Woolwich Council meeting with both local media present. They are trying to intimidate Dr. Holt into backing down from his opposition to granting verification to Chemtura. Shame on the company and shame on any organization which would support their behaviour.