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Third Party Verification

About Responsible Distribution | Supplier-Nominated Verification

NACD's Responsible Distribution requires two separate third-party verification processes that are conducted by independent third-party verification firms designated by NACD:

Document Verification 

The purpose of the Responsible Distribution Document Verification is to review documented policies and procedures for NACD's Responsible Distribution for all NACD Candidate members and Chemical Handler Affiliates (CHAs). The Document Verification will include:

  • Document Verification contract and payment
  • Company Profile Questionnaire: Provides a written overview of the company's operations, management structure, product lines, etc.
  • Self Assessment Report: Determines if the company has reached Stage V on all applicable elements of the Responsible Distribution Code of Management Practice.
  • Documented Responsible Distribution policies and procedures for requested codes, demonstrating consistency with the spirit and intent of the Code of Management Practice and/or are representative of the functions and facility usage described in the company profile.  A sample of each of four (4) sections selected will always include at least one (1) of the following Core Codes:
    • Compliance Review and Training
    • Handling and Storage
    • Job Procedures and Training
    • Emergency Response and Public Preparedness

and will also include (3) randomly selected sections of the Code of Management Practice.

NACD Candidates and CHAs mail their required documents to the designated third party verifier.

Process Timeline for Responsible Distribution Document Verification

Calendar Days

(following the items indicated above)

Activity

30

The verifying firm completes review of Company Profile, Self-Assessment Report, and requested Responsible Distribution policies and procedures.

35

The verifying firm recommends NACD Candidate or CHA for a verification “pass” and notifies NACD OR the verifying firm notifies applicant with a request for additional documentation or corrective action recommendation (applicant has 30 calendar days to submit additional documentation to verifying firm).

65

Last day for NACD Candidate or CHA to submit additional documentation that was requested (if previously indicated by verifying firm).

75

The verifying firm completes review of additional documentation (if indicated by verifying firm) that was requested, verifies resolution of request or corrective action recommendation, or issues a failed verification (and informs NACD). The verifying firm issues Document Verification certificate to applicant and copies NACD on status.

Note:  'Calendar Days' represent the last day on which these requirements can be met.

Site Verification

NACD's on-site third-party verification process is required of each NACD member at one of its distribution locations. Responsible Distribution verification is conducted by an independent, third-party verifier(s) against a standard specifications document based on the Responsible Distribution Guiding Principles and a Code of Management Practice. Responsible Distribution verification IS NOT an inspection against a rigid set of Yes/No questions that leave no flexibility for response. For example:

  • Responsible Distribution verification will verify that a member company has a system in place and is being implemented to provide for compliance with federal regulations.
  • Responsible Distribution verification is not a review of your company's actual compliance against specific regulations.
  • Responsible Distribution verification will verify that a member company has a system in place to identify/determine the skills and knowledge required to perform job responsibilities, and/or that programs are in place to ensure employees are properly trained.
  • Responsible Distribution verification does not evaluate your company's individual employee skill levels

NACD members and Chemical Handler Affiliates (CHAs) will began the fifth Responsible Distribution verification cycle on January 1, 2014 with on-site verifications. NACD initially contacts members and CHAs and the verifiers will follow up. The fifth cycle is the most robust and rewarding for NACD members, who expect to receive a more thorough assessment of their Responsible Distribution verification implementation and of their approach to environmental, health, safety, and security management.
 

Third Party Verifiers

For document verification, each applicable Candidate and Chemical Handler Affiliate will enter into a contractual agreement directly with one of the verifying firms below, assigned by NACD, that will identify payment terms and specifics regarding confidentiality and indemnification. All costs associated with the compliance verification process will be the sole responsibility of each member company as outlined in the contract.  The cost for the initial document verification review will be $690 (effective January 1, 2013) . A member company will incur an additional charge for re-evaluation if it is found to be non-compliant after the initial review and sixty-day period of corrective action.

The same verifiers are contracted by NACD for thid party site verification.  For more information, including costs, please contact NACD.

Compliance Solutions Group
Primary Contact: Dennis Zito
16851 Jefferson Hwy, Suite 6D
Baton Rouge, LA 70817
225/754-0405
Fax: 225/754-0406
dzito@compliance-sg.com

Eagle Group USA
Primary Contact: Deborah Iafrate
6001 North Adams Rd, Suite 205
Bloomfield Hills, MI 48304
248/355-4421
Fax: 248/355-4623
Deborah.Iafrate@eaglegroupusa.com

 

Be sure to visit the Responsible Distribution Resources page for more helpful information and assistance.


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