Business toll

All five elements combine to help ensure that the tolling operation is performed safely, efficiently, and in an environmentally sound manner. The ultimate reward to industry for embracing applicable good practices presented in this guideline is a vibrant business with minimized risk. The flowchart on page 3 shows the basic process for tolling as presented in this guideline. 

When would a company want to engage in tolling What could make a specific toller attractive to a client Here are some basic business... 

Equipment—client may not have the equipment required to manufacture a specific product. It may be that available capital and installation time are limited such that they simply can not design, acquire, install and test the process equipment to reach the desired capacity within the available budget and time. If a product is in the early stages of its life cycle, the capital required may be hard to justify. This could be based upon the low initial volume anticipated while developing the market or the need to take advantage of a time-sensitive business opportunity. Tolling can provide a means to safely produce introductoiy, short-term, or small volume products that would otherwise be uneconomic. 

Attached is our businesses Technolog Package Request. This information will be helpful m allowing us to meet your needs and expectations by selecting an appropriate toller. Our department developed this list to identify issues to consider m the tolled manufacturing of your product. Any information that you are able to provide will help us considerably and expedite our evaluation process. We look forward to working with you on this opportunity. 

If repetitive tolls are the norm for a client, a good way to screen candidate tollers is to make use of past experience. A satisfying business relationship between a toller and a client is a prelude to the continued use of a toller and the toller s continued desire to meet a good customer s needs. 

In large companies that contract tolls (those with several business groups), inquiring within the company may turn up candidate tollers of which one business group was unaware. This can often aid in evaluating the candidates if good performance data is available as described in the previous section. 

One way to make the importance of this clear is by including a business ethics provision in the tolling contract. The CMA Responsible Care initiative can be called out in such a provision and applied to both parties in the contract if they have both subscribed to its code of ethics. This is discussed further in Chapter 3, Mutual Agreements, Obligations and Contract Considerations. 

The company seeking to toll internationally in this case will benefit from selecting an experienced team of reviewers with international experience. Tollers seeking business from foreign companies would benefit by recognizing these new aspects may present difficulties when their capabilities are being assessed. The candidate tollers could prepare information in advance that helps respond to these potential concerns. 

It is incumbent upon the toller to develop and follow internal management systems as appropriate to support business needs, production needs, process safety, environmental responsibility, and worker health. The selection process should have considered whether or not satisfactory systems are in place. Nevertheless, the contract or auxiliary documents may be the vehicle used to help ensure that the system reviewed is the system actually used for completing the toll in question. Within the process safety management system, the management of change and training elements are essential subsystems. 

This post-startup review team should report the results of their review to the management of the business unit responsible for the final tolled product. If operating parameters or equipment configurations different from those approved in the technology package, management should promptly assess any risk associated from the variances and either ... 

Considering the merchant nature of the tolling business, these informal communications must still respect the confidentiality concerns and restrictions on both parties. While specific experience in allied technologies often may not be disclosed, it is incumbent on both parties to establish means to convey critical safety issues without disclosure of otherwise confidential information. 

The issue that must be managed is the appropriate threshold to communicate the change and initiate appropriate approval processes. Tolls subject to regulatory requirements may use the regulatory guidance as the threshold for management of change processes other tolls must establish the threshold appropriate to process risks, quality systems, and business concerns. 

So my message to the chemical industry broadly and in particular to the segment of small businesses is to not let the PMN requirements limit your creative spirit in the development and commercialization of new chemicals. The Office of Toxic Substances in EPA stands ready to assist you at no cost in filling out the forms and distinguishing clearly what is minimally essential for risk assessment purposes from what is optional. We have trained consultants in the northeastern and mid-west sections of the country ready to travel to your location and advise you in a confidential way on PMNs. Our staff in Washington can be immensely helpful and you should feel free to discuss your specific situation with them. And, to top it off, we have one recently-retired experienced chemcial industry man concentrating his entire effort to assist the small business man in any TSCA-related matter. His name is Dr. Bob Toomey give him a call on the Industry Assistance Office toll-free line. 

Here is a list of chemical suppliers that are legitimate businesses. It is true that the DEA often sets up fake supply houses, giving great prices on hard to find items, such as lysergic acid, to lure underground chemists into traps. These suppliers listed below are not part of any law organization. They are major suppliers only. However, they are required by law to report sales of certain substances. Note 800 telephone numbers are toll free. 

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