1 European Awards 2010 1 F. MARCENAC, Ph. GAGNAIRE, Dr B. DESPRES, O LEMARIE, A LEPLAY, M CROZIER-PATOUX Responsible Care® European Awards 2010 CMR risk

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European Awards 2010

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F. MARCENAC, Ph. GAGNAIRE, Dr B. DESPRES, O LEMARIE, A LEPLAY, M CROZIER-PATOUX

Responsible Care®European Awards 2010

CMR risk managementCMR risk management

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RHODIA IN BRIEF

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● International chemical company with leading position in all core activities● Well-balanced presence worldwide● Wide variety of markets served

Chemistry is our world

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● Group which combines innovation and responsibility in business activities

● - a framework of commitments deployed throughout the Group

● Performance recognized by Rhodia's inclusion in the

Responsibility is our way

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55

20% turnover

EBITDA(1)

487€ million

Sales

4.011€ billion

Production sites

64Employees

13,850

Operating income

160€ million

New products launched in past 5 years

* Following reclassification of activities which have been or are in the process of being disposed of(1) Recurring EBITDA: before restructuring costs and other operating income and expenditure

Key figures for 2009*

world-wide

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Global presence

20% of sales35% of sales

28% of sales

45% of sales in regions with strong potential for growth

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North AmericaSales: €802 million1,600 employees

EuropeSales: €1.404 billion6,000 employees

Latin AmericaSales: €682 million

2,900 employees

17% of sales

Asia PacificSales: €1.123 billion3,100 employees

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Number 3

Ranking in key business areas

• High-performance silicasHigh-performance silicas

• Rare earthsRare earths

• Diphenols for vanillinDiphenols for vanillin

• Specialty surfactants and Specialty surfactants and polymerspolymers

• GuarGuar and derivatives and derivatives

• Sulphuric acid regeneration*Sulphuric acid regeneration*

• CO2 emission credits (CERs)CO2 emission credits (CERs)

Sources: RHODIA estimates

• CelluloseCelluloseacetate towacetate tow

• Polyamide 6.6Polyamide 6.6• Engineering Engineering

plastics based on plastics based on polyamide 6.6polyamide 6.6

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Number 1 Number 2

* USA

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Responsibility rooted in Rhodia's culture

• Responsibility - the cornerstone of Rhodia Group culture

• Pioneer in commitment to Sustainable Development. Joined Responsible Care initiative back in 1985

• One of the world's best records in occupational safety• Rhodia Way: continuous improvement framework based on commitments to our stakeholders

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Rhodia's Management BookThe Management Book is designed to provide all Group employees with a framework for conducting their activities. It incorporates Rhodia's commitment to Sustainable Development and ensures compliance with the levels of corporate governance expected from a listed company. The Management Book embodies four objectives:

• Simplify and standardize common language and rules for the entire Group

• Strengthen managerial performanceThe Management Book describes methods which operate Group-wide. The 12 processes defined in the book are structured to maximize the effectiveness of teams by defining responsibilities and standardizing working processes. The Management Book also sets out the management rules which form the point of reference for the good practices which all managers must apply. Application of these rules strengthens discipline and aligns practices at each level of the Group's structure and is a key factor in efficiency.

• Provide clarityThe Management Book indicates who decides what and describes the 12 key processes which underpin the Rhodia organization.

• Controlling risks by an effective internal control systemEach individual responsible for a process must identify the risks associated with the practice of his/her activities, assess the severity of these risks and set the means in place to monitor and control them. The Management Book indicates the "Red Lines" which must be observed by all and which may incur severe penalties if they are crossed.

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Management of risks associated with CMR* substances: a major concern

• Management Book Red Lines

• What Rhodia defines as a CMR substance

• Scope of application

• List and track

• Status in 2009

• What needs to be done next

* Substances classed as Carcinogenic, Mutagenic or toxic for Reproduction

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CMR: a Management Book Red Line

• The red line relating to CMR substances is mandatory for all Group entities.

A thorough review must be conducted within three years of the A thorough review must be conducted within three years of the identification of a CMR substance, with the aim of eliminating identification of a CMR substance, with the aim of eliminating the substance or controlling the risk if the substance cannot be the substance or controlling the risk if the substance cannot be eliminated.eliminated.

The CMR red line means applying the principle which operates in Europe under the REACH regulations which requires authorization and seeking to identify substitutes for CMR SVHCs (substances of very high concern) on all sites where Rhodia operates world-wide.

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What Rhodia defines as a CMR substance

Step 1: Definition of criteria which can be adopted by a Group whose products are used throughout the world.

• Diversity of regulations in force in the countries where the group operates

=> need for a single CMR reference

• Establish definition of a CMR at group level:

• Substance which meets the criteria for classification as a category 1 or 2 CMR substance as defined in Annex VI of Directive 67/548/EEC (including substances which are self-classified by Rhodia or by another supplier).,

• Substance which meets the criteria for classification as a Group 1 carcinogen (carcinogenic for humans) or Group 2A carcinogen (probably carcinogenic for humans) according to the IARC classification system

• Substance or preparation containing one or more substances classed as CMR applying the criteria indicated above at a concentration equal to or greater than the concentration limits specified in the regulations.

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Control process on Rhodia sites Control process on Rhodia sites Flowchart for assessment of risks of Flowchart for assessment of risks of exposure to CMR substances exposure to CMR substances

Exhaustive and rigorous procedure for the assessment and control of CMR substance risks

applying the principles contained in Rhodia's integrated HIRA (Hazard applying the principles contained in Rhodia's integrated HIRA (Hazard Identification and Risk Assessment) management system.Identification and Risk Assessment) management system.

Recherche de CMR R45, R46, R49, R60 ou R 61

IARC groupe 1 ou 2A


IARC groupe 1 ou 2A

InventaireInventaire

Présence de CMR

Le site n'est plus concerné sauf gestion du passé


SubstitutionPossible ?

Le site n'est pas concerné sauf si CMR présents antérieurement


Évaluation des possibilités d'exposition


Substitution made

NO

YES

Not possible

FormationinformationFormation

information


IARC groupe 1 ou 2A

Identify CMR substancesR45, R46, R49, R60 or R 61

IARC group 1 or 2A

InventaireInventory

CMR substancepresent


Site only included for managing pastsituation

Substitutionpossible ?


Site not includedunless CMRmaterial presentpreviously


Assessment of possibilityof exposure

Substitution

N

Formationinformation

TrainingInformation

Évaluation des possibilités d'expositionÉvaluation des possibilités d'exposition

Les possibilités d'expositionpeuvent-elles être exclues

de façon certaine ?

Évaluation approfondie

Risque d'exposition

Risque acceptableEnregistrement et Archivage Maintenir la situation sous

contrôle


contrôle

Situationaméliorable / Indésirable


Liste des personnes exposées•Réduction des expositions immédiasi situation indésirable•Plan d'action si situation améliorabl

Enregistrement donnéArchivage

Enregistrement donnArchivage

YES

NO

Exemple : confinement total re-assessment

YES

NO

Évaluation des possibilités d'expositionAssessment of possibility of exposure

Can the possibilitiesof exposure be eliminated -

completely?

In-depth assessment

Exposure risk


contrôle

Acceptable risk Record and hold on fileKeep situation under

control


Unsatifactory /Scope for improvement

List of persons exposed•Reduction of immediate exposureif situation unsatisfactory•Action plan if can be improved

Enregistrement donéeArchivage

Record dataFile

e.g. total containment

Regular

N

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Reagents used in testing and

R&D laboratories

Raw materials

Intermediates

Processing aids

Wastes

Marketed products

R&D centres Production sites

Production sites Marketing & Sales

Possible presence of CMR substances in value chain

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• Substance type • Raw material

• Isolated intermediate

• Non-isolated intermediate

• Finished product

• Waste

• Other products, such as solvents and reagents used in laboratories, or products used in maintenance work

• Activities examined• Process

• Research and Development: Laboratory and pilot unit

• Quality control: laboratory

• Maintenance

• Framework procedures• Management of risks associated with CMR substances

• Management of risks in the workplace associated with the use of CMR substances

• Management of risks for marketed CMR substances

Scope and framework procedure for CMR risk management

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• Target set in 2007: 100% of dossiers produced by end December 2009, including new CMRs introduced by the 30th and 31st ATPs*.

• Dossiers are not closed until all stages in their preparation have been completed • Number of CMR substances used

• Number of activities using the CMR substances

• Substitution or non-substitution briefing documents drafted (%)

• Number of risk assessments performed (%)

• Number of dossiers finalized (%)

• Management tools• Inventory of all substances used and manufactured on all of the Group's sites

(updated every 2 years)

• Quarterly report for monitoring application of red line as closely as possible

• This ensures that each site is kept informed of progress on the CMR dossier relating to it

CMR dossier and management tools

* Adaptations to Technical Progress of Directive 67/548/EEC

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• Out of the 1,500 substances used or marketed by Rhodia, seven marketed substances have a CMR risk associated with them. The annual volume of these substances is below 10,000 tonnes.

Action taken• 21 substances were identified as being CMR substances in 2007• Solutions involving substitution or halting marketing were identified for 14 substances • Production of certain substances was stopped, e.g. in France (acrylonitrile line) and in China (solvent

containing dimethylformamide)

• Products used on Rhodia sites: of the 140 CMR substances employed for less than 650 uses, 32 substances are used in quantities exceeding 100 kg/year and 10 raw materials alone account for an annual volume of almost 400,000 tonnes

Action taken

• Diatomaceous earth (CMR substance) replaced by perlite as filter medium on many sites.

• Change from fuel oil (CMR substance) to gas, also bringing reduction in CO2 emissions.

• Discontinuation of use of certain substances which are carcinogenic by inhalation in powdered form (cobalt sulphate, bichromates) and replacement with other solutions

• Elimination of unused CMR substances stored in laboratories

• Position in December 2009• 99% of risk assessments completed

• 98% of substitution or non-substitution briefing documents drafted

• 97% of CMR dossiers finalized, with target of 100% for end 2009

The total figure is around 1,000 dossiers.

Position at end 2009

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Initiatives undertaken by multi-disciplinary teams

Initiatives took the form of mini-projects with staff from the different entities concerned pooling their expertise and resources, i.e.:

• Health, Safety and Environment (HSE)

• Responsible Care Department's expertise in toxicology

• Responsible Care Department's regulatory intelligence

• Site and regional Occupational Health functions

• R&D

• Site analytical testing functions,

• Product Stewardship

• Site production and maintenance departments,

• Process managers,

• Business unit production management functions

• Responsible Care status reporting.

Staff have conducted studies on all CMR substances concerned at Rhodia sites

FinishedFinished products (<10 kt/yr)products (<10 kt/yr)Raw materials & Raw materials & intermediates (≈ 400 kt/yr)intermediates (≈ 400 kt/yr)

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What needs to be done next

Complete all action plans already decided, plus:

• CMR substances produced and marketed by Rhodia• Employ the R&D process to challenge the use of CMR substances by initiating research

into alternative processes

• Work with our customers to look for substitutes and examining risk control for the CMR substances they use - this approach was first adopted in 2008

• Raw materials and reagents used on Rhodia SITES• Use solutions at concentrations which are below the CMR classification limits for

preparations.

• Continue investigations into substitute catalysts

• Contribution to reducing environmental impact (example)• Remediation of brown field sites: Scheduled investment for bio-remediation of leachate

on a waste site containing chromium VI using bacteria to convert this CMR substance into chromium III (a non-CMR substance)

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APPENDICES

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Summary of progress in creating CMR dossiers

• Almost 650 uses of CMR substances recorded

• For 140 CMR substances

(1) 30th and 31st ATPs included.

*

(1) (1)HEALTH & SAFETY RISK ANALYSIS2005 2006 2007 2008 (1) 2009 (1)

Number of uses of CMR substances on our sites (categories CE 1, 2, IARC 1 and 2a)

- 607 510 540 637

Number of activities concerned - 720 740 862 1 084

Substitution or non-substitution briefing documents drafted (%)

- 25% 67% 98% 98%

In-depth risk assessments performed (%) - 27% 68% 98% 99%

CMR dossiers completed (%) - 24% 63% 98% 97%

Current scope (2009)

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CMR - Quarterly report Q4 2009

Rhodia Group

Eco Services

Silcea Novecare Polyamide Research AcetowEnergy Services

SBU Salicyliques & Fluores

Q4 2006 * 25% 0% 3% 50% 7% 79% 0% 7%

Q4 2007 * 64% 21% 62% 43% 81% 87% 86% 59%

Q4 2008 ** 98% 86% 98% 100% 98% 98% 97% 22% 100%

Q1 2009 ** 92% 100% 86% 89% 95% 98% 97% 22% 93%

Q2 2009 ** 92% 100% 86% 90% 92% 99% 96% 22% 93%

Q3 2009 ** 94% 100% 96% 90% 93% 100% 96% 22% 93%

Q4 2009 ** 97% 100% 96% 99% 89% 100% 96% 100% 100%

Q4 2009 target 100% 100% 100% 100% 100% 100% 100% 100% 100%* data published at the end of year 2006, 2007 or 2008

** taking in account 30 & 31 ATP

Information issued to all personnel every three months and to stakeholders annually (Technical Sustainable Development report)

Consolidated CMR status worldwide

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97%

100%

96%

99%

89%

100%

96%

100%

100%

82% 84% 86% 88% 90% 92% 94% 96% 98% 100%

Rhodia Group

Eco Services

Silcea

Novecare

Polyamide

Research

Acetow

Energy Services

SBU Salicyliques & Fluores

97%

99%

99%

89%

98%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Rhodia Group

Europe

North America

South America

Asia Pacific

By Business UnitBy Business Unit

By geographic regionBy geographic region

Effective operational control through consolidation and progress reporting

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Classification of 140 CMR raw materials used by Rhodia*

CMRCMR Quantities used Quantities used annually (tonnes)annually (tonnes)

Number of sites where Number of sites where CMR substances are usedCMR substances are used

1-3 Butadiene1-3 Butadiene Confidential Confidential 33

Ethylene oxideEthylene oxide ConfidentialConfidential 88

Propylene oxidePropylene oxide ConfidentialConfidential 77

1.2-Dichloroethane1.2-Dichloroethane ConfidentialConfidential 44

FormaldehydeFormaldehyde ConfidentialConfidential 1616

2-(2-Aminoethylamino) ethanol (new 2-(2-Aminoethylamino) ethanol (new entry in 2008) entry in 2008) ConfidentialConfidential 11

ParaformaldehydeParaformaldehyde ConfidentialConfidential 11

EpichlorohydrinEpichlorohydrin ConfidentialConfidential 44

Benzyl chlorideBenzyl chloride ConfidentialConfidential 33

Diethyl sulphateDiethyl sulphate ConfidentialConfidential 66

• 32 CMR substances are used in significant volumes (> 100 kg/ yr) 32 CMR substances are used in significant volumes (> 100 kg/ yr)

• Top 10 significant users account for 94% of CMR substances usedTop 10 significant users account for 94% of CMR substances used

* 2008 data

Documents

1 European Awards 2010 1 F. MARCENAC, Ph. GAGNAIRE, Dr B. DESPRES, O LEMARIE, A LEPLAY, M CROZIER-PATOUX Responsible Care® European Awards 2010 CMR risk