ENVIRONMENTAL PROCEDURE - MIRMgatemirmgate.com.au/docs/Anglo_American/Incident_procedure_and... · ENVIRONMENTAL PROCEDURE ENVIRONMENTAL MANAGEMENT ... • environmental impact due

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ENVIRONMENTAL PROCEDURE ENVIRONMENTAL MANAGEMENT PROCEDURE S010 Environmental nonconformance and incident reporting

4. 1. 10.

Int. Date

REVISED

1. INTRODUCTION

Section 4.4.7 of the Environmental Management System standard ISO 14001 requires that the organisation shall maintain procedures for defining responsibility and authority for handling and investigating nonconformance and incidents, taking action to mitigate any impacts caused and for initiating and completing corrective and preventative action.

2. PURPOSE OF THE PROCEDURE

The purpose of this procedure is to provide guidance to all mine employees and contractors as to their responsibilities to the mine, fellow employees and colleagues in terms of the identification and reporting of environmental nonconformances and incidents on the site or related to mine activities. A “nonconformance” is interpreted to include legal noncompliance, deviations from policy, objectives and targets not met, accidents, ineffective procedures, deviations from specified conditions and from other requirements of the environmental system. The procedure has been developed so as to provide guidance to ensure that: • Danger to the environment, personnel, contractors and the non-employees is

minimized. • Legal liability is managed and minimized. • Public relations are effectively managed during and following a nonconformance. • Reporting is effective and corrective / follow-up actions are implemented.

3. EMERGENCY PROCEDURES

Major accidents and emergency situations (a chemical spill, hydrocarbon spill or leaks, surface fires including veld fires, slimes dam failure, spill or leak of process water or

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___________________________________ ____________________________________________ RESPONSIBLE MANAGER I RESPONSIBLE MANAGER ENVIRONMENTAL DATE : 10/13/05

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slimes, incidents involving radioactive material, etc.) are addressed in the Mine Emergency Preparedness and Response Procedure.

4. RESPONSIBILITIES FOR REPORTING AND INVESTIGATING

ENVIRONMENTAL NONCONFORMANCE Environmental non-conformance (as defined in paragraph 2) noted during environmental audits, along with corrective and preventive actions will be entered into the EMS database by the [RESPONSIBLE PERSON]. It is the responsibility of the line manager to secure action and report progress on a monthly basis until the non-conformance has been cleared. Typical nonconformances are: Nonconformance is listed in four categories: 1. Policy and Legal 2. People and Communication 3. Systems and Documentation 4. Materials and Processes 1. Policy and Legal • environmental policy commitments not addressed or fulfilled • environmental policy not communicated to employees • environmental policy statement not available to the public • relevant environmental laws not identified, understood or complied with • pollution discharges that are prohibited or exceed permitted legal limits 2. People and Communication • environmental responsibilities not defined, understood or exercised • inadequate authority delegated for effective control • environmental training needs not identified or planned • training not carried out or not effective • employees unaware of the environmental impacts and risks of their work • new employees ignored by the system 3. Systems and Documentation • no coordination - environmental objectives not reflecting policy commitments • no coordination - environmental actions not reflecting objectives • management programs not being reviewed to schedule

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• key documents unavailable, for example Environment Manual or Management Procedures

• unauthorized amendments in controlled documents • obsolete documents available in operational areas • emergency plans not tested or reviewed • corrective actions signed-off, but found to be ineffective in practice • environmental records not maintained up-to-date • retention times of environmental records not recorded • internal auditing running behind schedule • managers unaware of internal audit findings • decisions of the Management Review not carried out 4. Materials and Processes • major pollution event or pollution risk not identified or controlled • waste not controlled or segregated • major resource-use not identified or controlled • significance assessment of environmental aspects not based on risk factors • information on significant impacts or risks not kept up to date • environmental impact due to subcontractors not identified or controlled

Any nonconformance can be reported on an Incident Report or directly to the [Responsible Manager].

5. ENVIRONMENTAL INCIDENTS

The following occurrences are classed as environmental incidents: Spillage of fuel and lubricants. Spillage of chemicals and hazardous substances. Soil and water pollution. Dumping of scrap or waste in any area other than a designated scrap or waste disposal

sites. Littering. Disturbance of plants or animals without the necessary permits. Disturbance of historical and archaeological sites without the necessary permits. Unauthorised fishing and hunting. Unauthorised driving off existing tracks and roads.

Zero Tolerance means that ANY and EVERY impact on the environment must be reported and addressed immediately. No incident is to small or to big to report, whether it is one liter of oil that was spilled or 10 drums, it must be reported and rectified.

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6. ENVIRONMENTAL INCIDENT REPORTING

6.1. Incident Report Books All incidents must be recorded in the blue “Incident Report Books”, distributed mine wide by the Loss Control department. Three different coloured copies of the incident report form are available in the incident report books. The initiator of the incident keep the yellow copy of the incident report in his/her books. The white and blue forms of the incident report forms are given to the departmental Safety Officer and he distribute it as follows: The white page will be submitted to the supervisor in charge of the area where the

incident occurred. The blue form or a copy thereof is sent to the Environmental Department should the

incident be noted as an “Environmental Incident”. 6.2. Incident Assessment Form An Incident Assessment Form (see APPENDIX B) is required to be completed by the Environmental Department in conjunction with the respective line managers when a High Risk Incident has taken place. The original Incident Assessment Form will be retained by the [Responsible Manager] and copies will be forwarded to the relevant HOD and the line manager for filing. All level 2 and 3 incidents will be reported within 24 hours by fax and telephone to the Department of Water Affairs and Forestry, the Department of Environmental Affairs and Tourism and the Department of Minerals and Energy (see procedure on Emergency preparedness and response). In the event of an Environmental Incident the following procedure is followed (a schematic procedure can be seen in APPENDIX A):

4.1. Person causing or observing the incident

Shall report the incident to the Safety Officer in the Business Area.

4.2. Line Management in whose area of responsibility the incident took place

Shall investigate the incident, including; how it happened, the reasons it happened, how rehabilitation or clean up needs to

take place, nature of the impact that took place, type of work, process, equipment

involved, recommendations to avoid future

occurrences.

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Shall inform the Safety Officer on a daily basis of all incidents that was reported in the Business Area. Shall consult the Environmental Section for recommendations on actions to be taken where appropriate (e.g. clean-ups). Shall assist the Resource Manager Environmental with applicable data in order to enter the incident into the EMS database.

4.3. Safety Officers Shall forward a copy of the incident form to other line managers. Shall forward a copy of the incident form to the [Responsible Manager]. Shall inform the Environmental Department on a weekly basis of the incident by e-mail or a copy of the incident report. Once a High Risk Incident (any incident which results from a significant aspect and has the potential to cause a significant impact on the environment) occurred it must be reported immediately to the [Responsible Manager] by telephone or email. Shall forward a copy of the completed Incident Reporting form (and where applicable a copy of the incident investigation) to the Environmental Department.

4.4. Responsible Manager (Environment)

Shall complete the incident assessment form in APPENDIX B (Once a High Risk Incident was reported by the Safety Officer), to access whether the potential High Risk Incident will result in a Level 1, 2 or 3 category. Once a level 2 or 3 incident occurred it will be reported to the authorities as stated in the Emergency Preparedness and Response Procedure.

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Shall make recommendations for clean-up and/or appropriate alternate actions. Shall enter actions necessary to remediate environmental impacts into the EMS database in conjunction with the responsible line manager. Shall enter the incident onto the EMS database in order to monitor the root causes of incidents. Shall highlight the incidents for discussion at the monthly SHER meeting and the quarterly Steering Committee meeting.

7. ENVIRONMENTAL INCIDENT FOLLOW-UP

Recommendations for clean-ups or solutions to problems caused by environmental incidents will be co-ordinated by the Environmental Department. Actions (e.g. pollution clean-up) necessary to remedy the situation are entered into the EMS database by the Responsible Manager Environmental and the line manager responsible for the area concerned. Line Managers will be responsible for all follow-up action relating to the incident.

8. ENVIRONMENTAL INCIDENT REPORT AND INVESTIGATION RECORDS

Records of environmental incident reports and investigations are kept in accordance with the Environmental Management System Records Procedure.

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APPENDIX A:

Incident Reporting SystemIncident Reporting SystemIdentifiedProblem

IncidentReport

ImmediateCorrective

Action

Initiator

IR Root causeinvestigation

ACTION

ACTION

ACTION

Determine:•Validity•Preventive Action•Responsibility•Time frame

RME Check up

Not Valid

Determineeffectiveness of

preventive action after a period of

time

Effective

YES

NOFeedback

GOOD YESNO

Complete Incident Report

Dec

ide

on im

med

iate

actio

n to b

e tak

en

Take action

•Env Impact of Actions

Corrective & Preventive Action

Take

Further Action

SAFETYOFFICER

Updateon

Database

Updateon

Database

If high

risk,

repo

rt

imm

ediat

ely to

RM

E

Date: 9 July 2001 (uncontrolled copy)Ref no.: BRPMir.v 1.1

CloseIncidentReport

High Risk Incidents:any incident which derivefrom a significant aspectand have the potentialto cause a significant impact on the environment

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APPENDIX B: Incident Assessment Form

Environmental Incidents

REF NO……………….. 1. INCIDENT DETAILS AS REPORTED TO RME1

REPORTED BY DATE

DESCRIPTION OF INCIDENT:………………………………………………………………… ……………………………………………………………………………………………………... LOCATION OF INCIDENT: …………………………………………………………….. DATE OF INCIDENT: …………………….. TIME OF INCIDENT: ……………………… OTHER COMPANY INVOLVED: YES NO NAME: PUBLIC COMPLAINTS / OR ADVICE: YES NO NAME: GOVERNMENT INVOLVEMENT: YES NO DATE: TIME CONTACT

2. RME REPORT TO PERSONNEL NOTIFIED:

DATE NAME DEPARTMENT

81 Responsible Manager Environmental


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3. RME VISITS SITE OF INCIDENT INCIDENT DESCRIPTION: ……………………………………………………………………………………………………... ……………………………………………………………………………………………………... DESCRIPTION OF RECEIVING ENVIRONMENT: ……………………………………………………………………………………………………... ……………………………………………………………………………………………………... (Attach photo’s and weather details where applicable) DOES THE INCIDENT CAUSE AN IMPACT ON THE FOLLOWING: PARAMETER STATUS

1. Air Yes No

2. Land Yes No

3. Water Yes No

4. Fauna & flora Yes No

5. Community Yes No

6. Other:

……………..………..

Yes No

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COMPLETE THE FOLLOWING TABLES FOR EACH “YES” USING THE CRITERIA IN ATTACHMENT 1 DESCRIPTION OF IMPACT ON AIR: ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)

Significance (a+b+c) x d

Corrective action required

AAplc Level 1, 2 or 3

(e)

YES NO

DESCRIPTION OF IMPACT ON LAND: ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)




(e)

YES NO

DESCRIPTION OF IMPACT ON WATER: ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)




(e)

YES NO

DESCRIPTION OF IMPACT ON FAUNA & FLORA: ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)




(e)

YES NO

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DESCRIPTION OF IMPACT ON COMMUNITY: ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)




(e)

YES NO

DESCRIPTION OF IMPACT ON OTHER PARAMETER SUCH AS:……………………… ……………………………………………………………………………………………………...

Extent (a)

Duration (b)

Severity (c )

Consequence (a+b+c)

Probability (d)




(e)

YES NO

Average AAplc Level: ……..

DESCRIPTION OF CUMMULATIVE IMPACT: ……………………………………………………………………………………………………... ……………………………………………………………………………………………………... ……………………………………………………………………………………………………... COMMENTS: ……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

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COMPLETE THE CORRECTIVE ACTION SHEET:

CORRECTIVE ACTION:

Taken by: Position: Date:

CORRECTIVE ACTION FOLLOW-UP:

TYPE OF IMPACT MITIGATION* COMMENT

IMPACT ON AIR RECTIFIED YES NO N/A

IMPACT ON LAND RECTIFIED YES NO N/A

IMPACT ON WATER RECTIFIED YES NO N/A

IMPACT ON FAUNA & FLORA

RECTIFIED

YES NO N/A

IMPACT ON COMMUNITY

RECTIFIED

YES NO N/A

IMPACT ON ……………………….

RECTIFIED

YES NO N/A

Taken by: Position: Date:

CLEARED BY RME: DATE:

SIGNATURE:

COMMENT:

* IF “NO” REPEAT CORRECTIVE ACTION COMMENTS: ……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

……………………………………………………………………………………………………...

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ATTACHMENT 1: EVALUATION CRITERIA: Spatial(extent): The extent of the impact: • Within the immediate extent of incident • Within boundary of mine area • Outside mine area • Regional/global Scale: 1-4 (with 1 for immediate impact and a 4 for regional/global) Duration: Whether the impact is: • short term (0-24 hours) • medium term (>1 day) • long term (> 1 year) • permanent Scale: 1-4 (with 1 for short term impact and a 4 for permanent impact) Severity: Whether the magnitude/size of the impact is: • negligible (1) • low (5) • medium (7) • high (10) Scale: 1- 10 (with 1 for negligible severity and a 10 for high severity) Consequence: The sum of the Extent, Duration and Severity of the impact gives

the consequence of the impact. Probability: The likelihood of the impact repeats itself again: • improbable (0.1) • probable (0.5) • highly probable (0.7) • definite (1) Significance: The significance of the impact is the probability multiplied by the

consequence: • Level 3: significant (>12) • Level 2: moderate (6-12) • Level 1: minor (< 6) NOTE: All level 2 and 3 incidents need to be reported to Anglo Platinum Head Office and to the relevant Government Departments.

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ATTACHMENT 2: APPLICABLE DEFINITIONS: Aspect: An environmental aspect refers to an element of an

organisation’s activity, product or service that can have a beneficial or adverse impact on the environment.

Impact: An impact refers to the change that takes place in the

environment as a result of the aspect. Environment: Surroundings in which an organisation operates, including

air, water, land, natural resources, flora, fauna, humans and their interrelation. (The above three definitions are adopted from the SABS ISO 14001-standard).

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ATTACHMENT 3: Environmental Incidents and Complaints as per AAplc

Parameter Definitions

Level 1 incidents No of incidents during the reporting period that resulted in: • a minor impact on the physical or biological environment

(air, land, water or habitats) with no significant or long-term impairment of ecosystem function or surface/ground water resource; AND/OR

• an inconvenience/disturbance/disruption/annoyance (including odour, dust, noise, traffic problem, loss of water supply) of short duration and with no long-term effect on the community; AND/OR

• a release of material (gas, liquid, solid) or energy which has the potential to cause illness, injury or property damage to the public, or one which causes short-term discomfort or reversible health effect to the public; AND/OR

• minor repairable damage to commonplace structures of cultural significance, or minor infringement of cultural values; AND/OR

• isolated public complaints Level 2 incidents No of incidents during the reporting period that resulted in:

• a moderate impact on the physical or biological environment (air, land, water or habitats) with limited impairment of ecosystem function or surface/ground water resource; AND/OR

• a minor impact to fauna or flora in a statutory designated area (eg: National Park); AND/OR

• an inconvenience/disturbance/disruption/annoyance (including odour, dust, noise, traffic problem, loss of water supply) of moderate duration or with medium-term effect on the community; AND/OR

• a release of material (gas, liquid, solid) or energy which causes severe but reversible illness, non-disabling injury or moderate property damage to the public; AND/OR

• damage to rare structures of cultural significance, or significant infringement of cultural values/sacred locations; AND/OR

• attention from local media or widespread complaints

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Level 3 incidents No of incidents during the reporting period that resulted in: • a significant impact on the physical or biological

environment (air, land, water or habitats) with extensive or long-term impairment of ecosystem function or surface/ground water resource; AND/OR

• an impact to unique or protected species or habitats; AND/OR

• an inconvenience/disturbance/disruption/annoyance (including odour, dust, noise, traffic problem, loss of water supply) of long duration or with long-term effect on the community; AND/OR

• a release of material (gas, liquid, solid) or energy which causes chronic illness, permanent disabling injury, fatality or extensive property damage to the public; AND/OR

• irreparable damage to highly valued structures or sacred locations; AND/OR

• public or national/ international media outcry

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Disclaimer

As contributors of this information, Anglo American plc or any of its Group companies or their servants, agents or contractors, (generally referred to as the Company), are not responsible for any actions (or lack thereof) taken as a result of the information contained herein and the Company cannot be held liable for any damages resulting from reliance on or use of this information. Without limiting the above, as contributors, the Company shall have no responsibility for any act or omission of any other contributor. It is recorded that this material is presented for information purposes only, in the interests of sharing good practice. Whilst the information may be regarded as indicative of good practice, and effort has been made to ensure that it is accurate, no representation or warranty, express or implied, is made as to the accuracy, currency or completeness thereof. It is provided solely on the basis that users will be responsible for making their own assessments of the information. Users are accordingly advised to obtain independent advice before acting on the information contained herein, and to take specific advice from a qualified professional when dealing with specific situations. The Company will accordingly not accept any liability for any loss or damage of any kind whatsoever (including consequential loss), suffered by any person acting in reliance upon the information, howsoever such loss or damage may have been caused or sustained. The Company expressly disclaims liability for any such loss or damage. By accessing the information presented on the terms and conditions indicated, the user hereby indemnifies and holds the Company harmless against all such loss or damage.

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