ERCO Worldwide has undergone numerous name changes, ownership and management
organizations in its long history. It is now back to the ERCO nomenclature that focuses
on the fundamental aspect of its business, that of the electrolysis of sodium chloride
solution (brine) to produce sodium chlorate, used as a bleaching agent in pulp mills.
Over the years the company has acquired additional facilities and also introduced new
product lines.

On June 14th, 15th and 16th, 2004 the reverification team visited Nacan Products
Ltd. (Nacan) facilities in Brampton, Ontario and Boucherville, Quebec to conduct
interviews and review management systems and documentation pertaining to the
reverification protocol for 2002 through 2005.

The verification team selected by The Canadian Chemicals Producer's Association has
done a re-verification of the Responsible Care conformance of the company Basell Canada
Inc. on March 9,10 and 11 2004.

Basell is a multinational company doing business around the world. The re-verification
process was only done for the Canadian entity. Basell Canada Inc. owns two
manufacturing sites in Canada. The first one is located in Varennes Quebec and the other
one in Sarnia, Ontario. The Varennes site manufactures several types of polypropylene
and the Sarnia site operates an Isopropanol plant on behalf of their neighbour Shell
Canada above and beyond a polypropylene manufacturing plant. The company description
including its Canadian activities is described in appendix 1.

At Imperial Oil Chemicals (IOC) there are three management systems in place
based on ISO 14001, Operational Integrity and Responsible Care®. These
three systems are linked and supplement one another to provide an overall
management system that supports all the code requirements and ethic of
Responsible Care®. This management system has all components of the plan,
do, check and act continuous improvement process and provides IOC with a
self-healing management process. It must be noted that while IOC is embedded
in the Imperial Oil Limited (IOL) Sarnia complex, not all portions of IOL
operations are required to conform to the Responsible Care® requirements of
the Canadian Chemical Producers’ Association (C.C.P.A.).

Not until near the end of the verification, when the team were able to have a final
caucus, did the team conclude that the company is in fact following the
principles of Responsible Care, but by a shoestring. During the two day visit the
team swayed in either direction of compliant or not compliant.