APPENDIX C. 1) Environmental Management Plan 2) Emergency Response Plan 3) Register of Relevant Metal Concentrators Documents and Procedures

Transcription

1 APPENDIX C 1) Environmental Management Plan 2) Emergency Response Plan 3) Register of Relevant Metal Concentrators Documents and Procedures

2 Metal Concentrators (SA) (Pty) Ltd ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE OPERATION OF METAL CONCENTRATORS, ERF 17210, 23 NATAL STREET, PAARDEN EILAND, WESTERN CAPE PROVINCE August 2016 SEC REFERENCE NUMBER: AEL No.: TBA PO Box 30134, Tokai, 7966 Telephone: , Fax:

3 - 2 - TABLE OF CONTENTS 1. INTRODUCTION PROJECT DESCRIPTION LEGAL FRAMEWORK STATUTORY OBLIGATIONS POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION OVERVIEW OPERATIONAL PHASE MITIGATION MEASURES Atmospheric Emissions and Air Quality Health and Safety Impacts on Staff Soil and Freshwater Contamination Noise Impacts Waste Management Fire Safety Safety and First Aid DECOMMISSIONING PHASE IMPACTS Social Considerations Appropriate Machinery Plant and Equipment Strip-out Considerations Waste Management Storm water Fire Safety Safety and First Aid Air Quality Noise and Vibration Light Pollution Traffic Control IMPLEMENTATION OF THE EMP ROLES AND RESPONSIBILITIES, INCLUDING MONITORING AND AUDITING DOCUMENTATION AND RECORD KEEPING ENVIRONMENTAL AWARENESS AND TRAINING MATTERS PERTAINING TO NON-CONFORMANCE ONSITE... 22

4 - 3 - List of Annexures Annexure A Glossary Annexure B Possible Method Statement Template Decommissioning Phase Annexure C Role of the Environmental Control Officer (ECO) Decommissioning Phase Annexure D Site Layout Plan Annexure E Standard Operating Procedures and Preventative Maintenance Plans: 1) Emergency Response Plan 2) Risk Assessments 3) Abatement system Maintenance Checklists (scrubber and Baghouse) 4) Incident Investigation and Preventative Action Procedure Annexure F Incident Register and Basic Accident Register Templates IMPORTANT NOTE: ALL READERS TO PLEASE FAMILIARISE THEMSELVES WITH THE RELEVANT TERMINOLOGY CONTAINED IN THE GLOSSARY (APPENDIX A) PRIOR TO READING THIS DOCUMENT.

5 INTRODUCTION 1.1 Project Description Metal Concentrators (SA) (Pty) Ltd (Metcon) is a precious metal refining enterprise that is operating on Erf 17210, 23 Natal Street, in Paarden Eiland. Precious metals comprising scrap jewellery and gold and silver offcuts are received from jewellery workshops. These are chemically refined and processed after which they are cast into ingots. Metcon was established on the current site in 2004 in Cape Town to provide a precious metals refinery to service the local jeweler s workshops in Cape Town and the broader Western Cape. 1.2 Legal Framework This Environmental Management Programme (EMPr) has been compiled in fulfilment of the requirements of Section 22A (f) of the National Environmental Management: Air Quality Act, Act No. 39 of 2004, as amended (NEMAQA). The EMP should also adhere to the local authority by-law requirements as well as any other obligatory environmental and other legal requirements (see Section 2 of this EMPr). It is understood that Metal Concentrators (SA) (Pty) Ltd or any future development entity (where transfer of ownership occurs) will be fully responsible for this EMPr and its requirements including any environmental rehabilitation that may be needed. This is required in terms of Section 28 (Duty of Care and Remediation of Damage) of the National Environmental Management Act, (Act No. 107 of 1998), as amended.

6 STATUTORY OBLIGATIONS The applicant should adhere to any statutory requirements which may be relevant to the lifecycle of the Metcon facility, contained in: The National Environmental Management Act, Act 107 of 1998, as amended (NEMA). National Water Act, Act 36 of 1998, as amended. National Environmental Management Waste Act, Act 59 of 2008 Waste Classification and Management Regulations, August 2013 National Norms and Standards for the Assessment of Waste for Landfill Disposal, August 2013 National Norms and Standards for Disposal of Waste to Landfill, August 2013 All relevant by laws and building regulations of the City of Cape Town Relevant SANS codes The Operational Health and Safety Act, Act 85 of The National Environmental Management Air Quality Act, Act No. 39 of 2004 All associated frameworks, regulations and associated legislation

7 POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION OVERVIEW A variety of potential impacts are associated with the operation of the Metcon facility. Reference is made to the EIA Report and appended specialist studies, which form part of the submission made to City of Cape Town s Air Quality branch in support of Metcon application for an Atmospheric Emissions Licence in terms of Sections 22A of the National Environmental Management: Air Quality Act, Act No. 39 of 2004 (NEMAQA), as amended. A number of mitigatory measures are proposed to minimise impacts during the operational phase. It is understood that the applicant, Metcon, is responsible for any environmental rehabilitation as identified. 4.1 CONSTRUCTION PHASE MITIGATION MEASURES The Metcon facility is already operational and therefore no construction is to take place. Therefore the following EMPr focuses on the operational phase mitigation measures in relation to the precious metal refining process undertaken on the Metcon site. 4.2 OPERATIONAL PHASE MITIGATION MEASURES The following risks have been identified as associated with the Metcon precious metal refining operation: Atmospheric Emissions and Air Quality The activities undertaken on site have the potential for associated air quality impacts require licensing in terms of the National Environmental Management: Air Quality Act, Act No. 39 of 2004 (NEMAQA). Atmospheric emissions from the facility have the potential to adversely impact the lifestyle of residents in the nearby residential areas, due to adverse impacts on visibility. Emissions can have associated localised negative health impacts at sufficiently high concentrations. Cumulative negative impacts on air quality in the region, with associated broader-scale, longer-term negative health impacts for residents, can also be associated with unacceptably high concentrations of such emissions. And emissions of sulphur dioxide, hydrogen chloride, chlorine, hydrogen fluoride and ammonia are important air pollutants contributing to eutrophication and acidification of environmental systems when released into the atmosphere. Excessive emissions of these compounds and of particulate matter (PM) can settle on the rooftops and surfaces of the plant, surrounding enterprises and residential homes. Corrosion and damage to infrastructure could then occur. In addition, incident rainfall will then

8 - 7 - transport (in very dilute form) the acid and particulate into the stormwater system and on into receiving water bodies, with possible negative effects on freshwater or marine ecosystems. Whilst the impacts described above are possible, they are considered to be negligible based on the dispersion modelling and Atmospheric Impact Report completed by the air quality specialist findings and the small throughput of the facility. Best practice does require, however, that emissions are managed to meet the minimum emissions standards. Objectives: To avoid nuisance / lifestyle, health and acid rain impacts associated with atmospheric emissions from the Metcon facility. Targets: To comply with the minimum emissions standards for Precious Metal Refineries. To ensure that all aspects of the plant, including those aspects not subject to statutory limits, are subject to best practice management measures. Measures: All emissions from the facility are extracted through abatement systems, namely, a caustic scrubber and high efficiency baghouse filter in order to reduce and contain emissions from the facility to within limits set by the NEMAQA, Minimum Emissions Standards (MES). Emissions testing and an Air Quality Impact Assessment undertaken show that emissions are within the limits set by the minimum emissions standards. The proper maintenance of the abatement equipment allows the equipment to effectively capture airborne particulate from the air stream. (a) (b) To ensure that the abatement equipment functions as designed, preventative maintenance schedules are in place. The preventative maintenance schedules and the standard operating procedures/risk assessments contained in Appendix E of this EMPr must be adhered to as best practice means of avoiding excessive emissions Health and Safety Impacts on Staff The health and safety of employees can be adversely affected due to the hazardous nature of some of the inputs utilised, processes undertaken and plant and equipment at the precious metal refining facility, including:

9 - 8 - Use of acids and alkali s in chemical refining and exposure to metal fume and particulate matter presents the potential for lung damage and acid/alkali burns. Exposure to organic chemicals can occur in the workshop and mould making areas, which could result in adverse health impacts. High temperature work including all works at the refinery related to melting and casting of the precious metals can be hazardous. Objectives: To avoid negative impacts on the health and safety of staff due to exposure to hazardous inputs, high temperature production processes, etc. Targets: To comply with the requirements of the Operational Health and Safety Act (OHS Act), to implement best practice operating procedures; and to ensure that the refinery extraction system is adequate to yield an acceptable indoor air quality. Operational measures: (a) The work areas and stations in the facility have local exhaust extraction points in order to ensure that employees working at the facility are not exposed to hazardous materials. (b) Risk assessments and preventative maintenance schedules have been included in Appendix E to mitigate potential health and safety impacts. These comply with the requirements of the OHS Act. (c) In addition, occupational health monitoring in terms of the requirements of the OHS Act is undertaken to ensure that indoor air quality is acceptable Soil and water Contamination There is some risk of soil and water (groundwater and stormwater) contamination associated with Metcon operations. This relates to possible impacts from the storage and handling of chemicals (e.g. acids and alkali s used in precious metal refining) and any hazardous wastes produced. Objectives: To ensure the local authority by-laws any other statutory requirements are adhered to. To ensure that any spills or leaks at the site from an incident or from day-to-day material storage and handling activities, are not able to reach any soil or groundwater or freshwater ecosystems nearby. To ensure that no pollutants reach the municipal storm water system which often discharge into freshwater ecosystems in natural drainage channels. And in the event of an incident, that prompt action is taken to remedy the cause of the spill or leak and to address any potential contamination and to take remedial action as required.

10 - 9 - Targets: To comply with best practice operating procedures and various authority requirements with respect to prevention of soil and freshwater (stormwater, groundwater, surface water) resources. Measures: (a) (b) (c) (d) (e) (f) (g) (h) (i) (j) Storm water systems should be designed to remove storm water adequately from the site. If the storm water is of such a quality that contamination could be present then detention measures and containment must be considered and implemented in order to prevent off-site pollution. All storm water channels and drains on the site should be inspected regularly to ensure that they are not blocked and/or obstructed to ensure their efficient operation. The preventative maintenance schedules and the standard operating procedures contained in Appendix E of this EMPr must be adhered to as a best practice means of avoiding spills, leaks, overfills or other incidents. All chemicals and hazardous wastes must be stored in a bunded area, exceeding the maximum total volume by 10%. The storage areas must be secured and adequate access control must be enforced. Material safety data sheets (MSDS) must be available on site where products are stored, so that in the event of an incident, the correct action can be taken. Any incident that results in ingress of product into the soil or water courses must be reported to all relevant authorities, including the DEA&DP s Pollution Management Directorate and the Department of Water Affairs, within 14 days. This is in compliance with Section 30 (10) of the NEMA and Section 20 (3) of the Water Act. The incident report must include the containment and clean-up procedure and the remediation procedure for the impacted area. Containment, clean-up and remediation must commence immediately. A spill response kit appropriate to the chemicals and wastes stored, handled and processed at the site must be kept at the site at all times. In the event of a spill or leak, the Emergency Response Plan contained in Appendix E must be implemented. A spill management protocol must be included in the Emergency Response Plan. An Environmental/Incident Register must be kept on site. Details of any incidences which may occur, as well as details on how the incident was rectified and / or remediated, must be included in the register. The register should also include chain-of custody receipts from disposal of hazardous waste; copies of any Section 30 Incident Forms which may need to be sent to the authorities in the event of an incident; results of on-going emission monitoring; details of complaints from neighbouring parties with respect to nuisance impacts such as noise or odours; etc and actions taken as required. The Environmental Register should be kept updated by the designated site Safety Officer.

11 Noise Impacts Industrial activities such associated with a precious metal refinery have associated noise impacts the operation of extraction systems, compressors, generators, etc. during operational activities. Due to the nature and scale of the operation, considered in the context of the industrialised surrounds, noise levels are not expected to be disturbing as defined in the Western Cape Noise Control Regulations, 2013 (i.e. to exceed ambient noise levels by 7dBA or more). Objectives: To avoid disturbing noise impacts on neighbouring facilities. Targets: To ensure that noise levels at the facility do not exceed ambient noise levels by 7dBA or more, in compliance with the Western Cape Noise Control Regulations, Measures: (a) The preventative maintenance schedules included in Appendix E will help ensure that equipment does not operate at elevated noise levels due to damage or failure. (b) Metcon needs to ensure that its extraction systems, compressors and generators are regularly serviced and maintained to ensure that they do not operate at elevated noise levels due to lack of maintenance Waste Management Objectives: To minimise possible environmental damage through inappropriate waste management on site or related to the facility during operational activities. Targets: To ensure that the handling of waste is in accordance with the statutory requirements of the local authority by-laws and the National Environmental Management Waste Act, Act 59 of Measures: (a) (b) (c) (d) An Integrated Waste Management Plan should be produced and implemented on site. Waste generated from the site should be classified in terms of the NEM: WA, Waste Classification and Management Regulations and associated Norms and Standards. The waste storage areas should be bunded and protected from the weather, specifically rainfall and stormwater ingress and egress. Chain of custody documentation must be provided to ensure a suitable end recipient for all waste disposed of.

12 (e) (f) (g) (h) Effluent or contaminated water should be stored in a suitable tank of adequate capacity to avoid overflows during heavy rainfall events until final disposal at a suitable and licensed disposal or recycling facility. An adequate number of waste receptacles must be provided for recyclables, general and hazardous waste at points around the facility. Waste is to be collected either by the Municipality or via a licensed waste disposal Contractor at a frequency to ensure that waste receptacles do not overflow. Used chemical containers should be safely closed and stored until return to the manufacturer for final disposal Fire Safety Objectives: To prevent any potential impacts related to fires originating on site during operational activities.. Targets: To ensure compliance with the local fire department and local authority by-laws and any other statutory requirements relating to fire safety. Measures: (a) No fires should be allowed on site. (b) Welding or cutting activities should be covered by a hot work permit. (c) Adequate firefighting equipment must be available on site and be in good working order. (d) Sufficient numbers of personnel trained in fire safety and familiar with firefighting equipment on site must be present on the site at all times. (e) Emergency fire response measures are included in the Emergency Response Plan in Appendix E Safety and First Aid Objectives: To minimise any potential safety or health related incidents on site during operational activities. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to health and safety on the decommissioning site. Measures: (a) All employees, contractors and agent/s shall at all times comply with the relevant statutory requirements including the Occupational Health and Safety Act, Act No.85 of (b) A comprehensive site specific first aid kit must be available on site at all times.

13 (c) Sufficient numbers of personnel trained in safety and first aid and familiar with the first aid equipment on site must be present on the site at all times. (d) Safety and first aid emergency procedures should be included in the Emergency Response Plan. 4.3 DECOMMISSIONING PHASE IMPACTS If the facility is decommissioned, similar impacts to those associated with a construction phase may arise. These impacts and the recommended mitigation measures are listed as follows: Social Considerations Objective: To minimise social impacts (e.g. nuisance factors) related to the decommissioning of the site through effective communications with abutting neighbours. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to site decommissioning and demolition impacts. Measures: (a) All abutting neighbours (or as required) must be notified of the proposed decommissioning phase activities at least two weeks before they commence. (b) The Contractor must record and repair any damage that the decommissioning works may cause to neighbouring properties. (c) An appointed ECO must be notified in writing of any incidents relating to the above Appropriate Machinery Objectives: To minimise possible nuisance affects and environmental damage through the use of appropriate machinery during the decommissioning works. Targets: To ensure that impacts and damage to the environment are minimised via the responsible use of appropriate machinery on site. Measures: (a) The Contractor shall at all times carefully consider what machinery is appropriate to the task in the context of this EMPr while minimising the extent of environmental impact. (b) A dedicated parking area must be defined with drip trays beneath any potentially leaking equipment and fuel/lubricant absorbing media (peat/moss type products) within these drip trays must be used to contain any spilled liquids.

14 (c) These materials must be replaced regularly to prevent over-saturation and potential spillage of free phase product. This material must be disposed of as hazardous waste and be collected by an approved Contractor/delivered to a suitable landfill site. (d) Chain of custody documentation must be provided as proof of final end recipient for material disposed of from the site. (e) All spills are to be recorded in an Environmental Register, including any clean-up actions taken to remediate the spillage. Such actions are to be agreed with the ECO prior to taking place Plant and Equipment Strip-out Considerations Objective: To minimise impacts related to the strip-out of plant and equipment from the facility, such as safe disposal of wastes/equipment generated and prevention of environmental impacts during decommissioning of equipment. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to site decommissioning. Measures: (a) All water, gas and electricity services for the equipment should be isolated, drained or vented if required and safely disconnected or removed. (b) All plant and equipment should be cleaned of all chemicals and materials. (c) All plant and equipment should be packed in appropriate containers and removed from site for transfer, sale or final disposal. (d) Any plant and equipment scheduled for final disposal or recycling should be send to a registered facility and proof of disposal obtained. (e) No hazardous plant, equipment or materials should be left on site Waste Management Objectives: To minimise possible environmental damage through inappropriate waste management on site or related to the facility. Targets: To ensure that the handling of waste is in accordance with the statutory requirements of the local authority by-laws and the National Environmental Management Waste Act, Act 59 of Measures:

15 - 14-1) Liquid Waste: (a) Liquid dispensing receptacles (e.g. lubricants, diesel, shutter oil etc.) must have drip trays beneath them/beneath the nozzle fixtures. (b) A spill management protocol must be produced by the Contractor and approved by the ECO prior to works commencing on site. (c) Material safety data sheets (MSDS) must be available on site where products are stored, so that in the event of an incident, the correct action can be taken. (d) Depending on the types of materials stored on site, suitable product recovery materials (such as Spillsorb or Drizit products) must be readily available. (e) Contaminated water must be fed to a container and suitably disposed of (e.g. sent to a suitable landfill site). In the latter case, chain of custody documentation must be provided to ensure a suitable end recipient. The latter must be kept with the environmental register. (f) The Contractor shall ensure that any wastewater generated during decommissioning activities feeds to a suitable containment area such as a container or lined sedimentation pond prior to disposal. This pond or ponds must be allowed to dry out on a regular basis to allow for solid material removal. The wastewater must be disposed of in a suitable manner (possibly to the sewer system following local authority approval) and must not be directed to a storm water drain. (g) Storm water runoff must be managed in such a way that no overland flow is possible onto any area of the site which could contain potential contaminants (such as concrete mixing areas, material and hazardous storage areas from any adjacent area). 2) Solid Waste: (a) Waste must be categorised by the Contractor and disposed of in a suitable manner into separate waste streams (this includes general, hazardous and recyclable waste) only at authorised waste disposal facilities. (b) The Contractor must provide an adequate number of waste receptacles for general waste at points around the decommissioned site as well as for hazardous and recyclable waste. (c) Waste is to be collected either by the Municipality or via a licensed waste disposal Contractor. (d) The frequency of collections/emptying of waste receptacles will be of such a frequency that waste receptacles do not overflow. (e) Particular care shall be taken with the disposal of materials that could be wind-borne or waterborne to ensure that the release of these materials is minimised (the latter is a requirement for hazardous waste). (f) The use of netting covers or similar sealed containers must be implemented as and when required by the ECO. (g) All material used by the Contractor during the decommissioning phase shall be managed in such a way that it does not cause pollution, or that it minimises pollution. In the event of a spillage, the Contractor should have suitably trained personnel who can correctly clean up any spillage in an efficient and environmentally sound manner.

16 - 15-3) Hazardous Waste: (a) Storage areas that contain hazardous substances must be covered and bunded with an approved impermeable liner or have some form of secondary containment. (b) The Contractor shall keep MSDS on-site for all potentially hazardous materials used. (c) Suitably trained personnel shall be available on the site during working hours so that in the event of human exposure to any hazardous materials that the correct first aid actions are taken. This training should also include environmental spill containment procedures (d) Spills in bunded areas must be cleaned up, removed and disposed of safely from the bunded area as soon after detection as possible to minimize pollution risk and reduced bunding capacity. (e) Chain of Custody documentation must be provided for any hazardous substances disposed of as proof of end recipient and disposal at an authorised hazardous waste disposal facility Storm water Objectives: To minimise potential impacts arising out of improper management of storm water originating on site. Targets: To ensure that storm water on site is managed according to the local authority by-laws and in accordance with any other statutory requirements and that no negative impacts occur to the storm water services around the site. Measures: (a) During decommissioning, all material excavated must be protected, screened or covered to prevent off site movement (primarily wind-blown soil or surface runoff) and the surplus material must be removed from site regularly to a licensed waste disposal site or re-used if appropriate. (b) All storm water channels and drains around the outside of the site should be inspected regularly to ensure that they are not blocked and/or obstructed to ensure their efficient operation. (c) Storm water runoff must be controlled to ensure that on-site activities do not result in off-site pollution Fire Safety Objectives: To prevent any potential impacts related to fires originating on site.

17 Targets: To ensure compliance with the local fire department and local authority by-laws and any other statutory requirements relating to fire safety. Measures: (a) No fires should be allowed on site. (b) Welding or cutting activities should be covered by a hot work permit. (c) Adequate fire fighting equipment must be available on site and be in good working order. (d) At least one person trained in fire safety and familiar with fire fighting equipment on site must be present on the site at all times Safety and First Aid Objectives: To minimise any potential safety or health related incidents on site. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to health and safety on the decommissioning site. Measures: (a) All people working on site are responsible for their own safety on site. Contractors and Agent/s shall at all times comply with the relevant statutory requirements including the Occupational Health and Safety Act, Act No.85 of (b) A comprehensive site specific first aid kit must be available on site at all times. (c) At least one person trained in safety and first aid and familiar with the first aid equipment on site must be present on the site at all times. (d) Emergency procedures must also be established prior to the start of decommissioning operations on site and appended to this EMPr Air Quality Objectives: To minimise potential air quality impacts during decommissioning related activities. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to air quality. Measures: (a) Wind-blown dust and sand may generate considerable negative impacts (e.g. reduced visibility for vehicles travelling along adjacent roads and nuisance to neighbours/adjacent erven). The use of water bowsers and wetting down of loose soil areas, as well as the

18 erection of shade netting screens to prevent off-site movement of dust is required and/or other appropriate action to minimise this impact. (b) The use of straw stabilisation or mulching of exposed sandy areas may also be considered in consultation with the ECO. (c) Water for dust suppression is to be sourced from non-potable sources as far as possible, e.g. the contractor can erect a rainwater harvesting tank on the site; and/or if there is a settlement pond on the site for excess cement mixing water runoff, the top layer of mixing water, where the fines have settled out, can be utilised for dust suppression Noise and Vibration Objectives: To minimise any potential noise impacts related to the decommissioning operations on site. Targets: To ensure compliance with all legal requirements, including the local authority by-laws and any other statutory requirements relating to noise impacts. Measures: (a) The Contractor must use appropriate, modern equipment, which produces the least noise. (b) The use of noise shielding screens should be considered by the project team as and when required. (c) The provisions of SABS 1200A Sub clause 4.1 regarding "built-up areas" shall apply to all areas within audible distance of residents whether in urban, peri-urban or rural areas. (d) No amplified music shall be allowed on site. The use of radios, tape recorders, compact disc players, television sets etc. shall not be permitted unless the volume is kept sufficiently low as to avoid any intrusion on members of the public within range. (e) The Contractor shall not use sound amplification equipment on site unless for the purposes of site safety and communications and in emergency situations. (f) Decommissioning activities shall be confined to the hours stipulated by the local authority. (g) The Contractor will issue ear protection for any noise activities with a noise output of 85 db or more. (h) The Contractor must notify all adjacent property owners/occupants of the proposed development and that noise impacts above 85 db may occur as a result of the above. (i) No noise generating work is to be conducted outside of approved working hours unless in consultation with the local authority and advised to the adjacent property owners/occupants prior to works taking place.

19 Light Pollution Objectives: To minimise light impacts associated with decommissioning related activities. Targets: To ensure that light pollution is minimised such that no complaints are received from the public. Measures: (a) All legal requirements will be complied with to ensure that impacts are minimised. (b) Any lighting required by the Contractor shall be aimed at the area to be lit on site and the over spillage must be kept to a minimum Traffic Control Objectives: To ensure that traffic impacts as a result of the decommissioning related activities are minimized. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to decommissioning traffic. To ensure that the impacts on current traffic flows in the vicinity of the site are minimised and that complaints relating to traffic associated with the site s activities are minimised. Measures: (a) Appropriate traffic routing and scheduling of decommissioning related vehicles will be carried out in consultation with a competent traffic engineer. (b) The contractor must provide a competent traffic marshal for situations where heavy decommissioning traffic may impede normal traffic flows on any roads adjacent to the site. (c) All vehicles will be legally compliant. (d) All drivers will be competent and in possession of an appropriate valid driver s license. (e) All vehicles travelling on site will adhere to the specified speed limits. (f) The movement of all vehicles will be controlled such that they remain on designated routes. (g) No member of the workforce will be permitted to drive a vehicle under the influence of alcohol or narcotic substances.

20 IMPLEMENTATION OF THE EMPR 5.2 Roles and Responsibilities, including Monitoring and Auditing Environmental Manager/Officer For Operational Phase (a) Emissions monitoring should be conducted at the facility as per the requirements of the AEL and relevant legislation. (b) Emissions reporting on the NAEIS system should take place as per the requirements of the AEL and relevant legislation. (c) At the frequency determined by the facility and if required, the licensing authority, the site should be audited against the conditions of the AEL by an appropriately qualitied and experienced auditor. (d) Audit reports must contain emissions reports, monitoring results, chain-of-custody receipts to show safe disposal of hazardous waste, incident reports from the environmental register, etc. (e) Annual compliance reports or any other reports requested in terms of the AEL should be submitted to the City s Air Quality branch for their records as required or requested. (f) All on-going emissions monitoring, plant upgrade and other management measures contained in the AEL, should be reported on to the relevant authority such as City of Cape Town s Air Quality branch by the facility, at the frequency determined by the licensing authority. Environmental Control Officer ( ECO ) For Decommissioning Phase (a) An ECO must be formally appointed to monitor and manage the relevant aspects of this EMP during the decommissioning phase. (b) The responsibilities of the ECO will include monitoring of compliance with the EMP by the facility, applicant and any sub-contractors during the decommissioning phase of the facility. (c) The ECO has the authority to recommend the cessation of works or any portion of the decommissioning related activity of the facility. This will be triggered if in his/her opinion the activity has caused or will imminently cause significant damage and/or harm to the environment or is in contravention of the relevant environmental legislation/permits/authorisations applicable to the site and/or activity/ies.

21 The Facility The facility is responsible for employing the ECO, Employees, Contractors and any Sub-contractors for the lifecycle of the facility. It is the facilities responsibility to ensure that all parties fulfil their obligations in terms of this EMPr, i.e. the implementation of this EMPr is the facility responsibility, and the facility must ensure that all activities taking place on the site are conducted in an environmentally responsible manner and in accordance with the requirements of this EMP. 5.3 Documentation and Record Keeping (a) List of onsite documentation An environmental register must be kept at the site, which must include the following: An accident and incident register; Complaints/Environmental register; Emergency Response Plan Site evacuation plan/maps; MSDS s In addition, to this EMPr, the Emergency Response Plan, as well as the Atmospheric Emissions Licence must be kept at the site. The right of the public to information shall be respected in accordance with relevant legislation. (b) Environmental Register The environmental register should be used to record any relevant daily information related to the operations and current status of the site, including the following information: Details of audits and inspections carried out by the Environmental Manager or ECO and/or as detailed in this EMPr and follow-ups Instances of non-conformances found in the EMPr, the date of their occurrence, date of corrective action, and date of completion of preventive action Any other relevant/pertinent daily events The environmental register should also contain the accident and incident register and/or the complaints register.

22 (c) Accident and Incident Register An accident and incident register must be kept and should include the following information (refer to Appendix F for templates): Time, date and place of the accident and/or incident Who and what was involved A detailed description of the accident or incident (d) Complaints/environmental register A complaints register must be kept for the recording of all complaints lodged regarding the facility. It is important that the complainant feels that their concerns have been listened to and that appropriate action (within reason) has been taken to address these. The complaints register must include: Details of the complaint in clear, well-structured language Time and date of complaint and details of complainant for follow-up purposes Name of the person who received the complaint Description of action that was taken to address the complaint, including date and time of action (e) Method statements will be required for activities that may result in significant impacts. These must address the following aspects: What a brief description How a detailed description of the process of work, methods and materials Where a description of the location of the work or equipment to be worked on All Method statements must be approved by the ECO prior to being implemented and must address the following: Health and Safety Environmental considerations Waste Management

23 Environmental Awareness and Training a) The Environmental Manager / ECO should conduct on-going Environmental Awareness Training sessions with staff and contractors during the both operational and decommissioning phases. This should be part of an induction process. b) For day to day operations at the site, it is the responsibility of the facility to ensure that all employees and sub-contractors are fully aware of the operational procedures that must be followed in order to minimise health, safety and environmental risks associated with operations at the facility. 5.5 Matters Pertaining to Non-Conformance on site Non-conformances would occur when there are deviations from any of the requirements of this EMPr. This may also include non-compliance with the relevant environmental regulations. In the event of identified non-conformance with the EMPr, the facility must, thereafter, undertake the following activities: Investigate and identify the cause of non-conformance; Implement suitable corrective action (appropriate to the magnitude of the environmental impact), as well as prevent recurrence of the problem, with responsibilities assigned for both. Non-conformances and corrective action must be recorded in the environmental register, and be included in the audit reports compiled by the Environmental Manager / ECO. During the operational phase, it is the facility s responsibility to audit and monitor the sites environmental system as required. The audit report must include any incidences of non-conformance and recommendations for any corrective action required. The facility must also comply with all requirements including, operational, plant and equipment, monitoring, reporting, etc. stipulated by the AEL. In addition, the facility, their contractors, sub-contractors and employees are legally bound by Section 24(h) National Environmental Management Second Amendment Act, Act No. 107 of 1998, which states that it is an offence for any person to contravene conditions applicable to any environmental authorization granted for a listed activity. A person convicted of an offence is liable to a fine not exceeding R5 million or to imprisonment for a period not exceeding ten years, or to both such fine and such imprisonment

24 This Environmental Management Programme, when approved, constitutes a Condition applicable to an Environmental Authorisation, Waste Licence or Atmospheric Emissions Licence and any transgression would thus trigger Section 24(h) of the above-mentioned Act. The exact penalty and fines will be decided on, subsequent to consultation with DEA&DP and the local municipality. All staff working on-site must be made aware of the consequences of non-conformance. EMP written by : David Spencer Report reviewed by: Adrian Sillito CEAPSA, Pr. Sci. Nat.

25 EMP ANNEXURE A GLOSSARY

26 TERMS USED IN THIS EMP The terms used include the following: The term facility means the owner of the facility to which this EMP applies. The term construction means all organised activities concerned with demolition, building, landscaping, maintenance, civil engineering, process engineering, heavy engineering and mining. The term contractor means an organisation that contracts with the applicant to carry out the work under a contract, including construction and other services. The term decommission means all organised activities concerned with demolition of infrastructure (above and below ground) on site as well as the associated removal of infrastructure on site as well as the rehabilitation and/or site clean up after infrastructure has been removed. The term design means the process (and product) of converting a brief into design details ready for documentation, including concept design and design development, and then documentation or detailing of the technical and other requirements for the project in a written form that details the project product sufficiently for it to be constructed or otherwise provided. The term environmental opportunity means a potential for beneficial environmental impacts (such as an improvement in air or water quality through environmentally friendly technology alternatives). The term environmental risk means a potential for adverse environmental impacts (such as pollution of a water source during decommissioning activities). The term management means the planning and interactive controlling of human and material resources to achieve time, cost, quality, performance, functional and scope

27 requirements. It involves the anticipation of changes due to changing circumstances and the making of other changes to minimise adverse effects. The term procurement means the collection of activities performed by and for an agency to acquire services and products, including assets, beginning with the identification/detailing of service requirements and concluding with the acceptance (and where applicable, disposal) of the services and products. The term project means an undertaking with a defined beginning and objective by which completion is identified. Project delivery may be completed using one contract or a number of contracts. The term service provider means a contractor, subcontractor, supplier, consultant (including an agency) and sub-consultant (contracting with a consultant), and their service providers, that contract with a customer to carry out construction, decommissioning, provide other products (including goods) and/or provide services. The term subcontractor means an organisation that contracts with a contractor as the customer to carry out construction and related services, and/or provide other products. The term supplier means an organisation that contracts with a contractor or Principal Agent to supply a product and/or service.

28

29 EMP ANNEXURE C ROLE OF THE ECO

30

31 DUTIES OF THE ECO 1. Ensuring that the decommissioning phase EMPr conditions are adhered to at all times and taking action where the specifications are not being followed. 2. Ensuring that environmental impacts are kept to a minimum. 3. Reviewing and approving method statements in consultation with the Principal Agent. 4. Advising the contractor on environmental issues and assisting in developing environmentally responsible solutions to problems. 5. Reporting to the applicant on a regular basis and advising of any environmental impacts. 6. Attending site meetings (when necessary) and giving a report back on the environmental issues at these meetings and other meetings that may be called regarding environmental matters. 7. Inspecting and auditing the site and surrounding areas regularly. 8. Establishing and monitoring an on-going environmental awareness program in conjunction with the contractor. 9. Requesting the removal of person(s) and/or equipment not complying with the specifications. 10. Keeping both a written and photographic record of progress on site from an environmental perspective, and an ad hoc record of all incidents or events on site with environmental ramifications. These records should be dated and accurately catalogued in the onsite logbook, and separate audit reports. 11. Undertaking continual internal review of the EMP and submitting a report at the end of the project. 12. The ECO will submit all written instructions and verbal requests to the contractor via the Principal Agent.

32 EMP ANNEXURE D SITE LAYOUT PLAN

33 EMP ANNEXURE E METAL CONCENTRATORS STANDARD OPERATING PROCEDURES AND PREVENTATIVE MAINTENANCE PLANS: 1) EMERGENCY RESPONSE PLAN 2) SPILL RESPONSE PLAN 3) ABATEMENT SYSTEM PREVENTATIVE MAINTENANCE CHECKLIST 4) REGISTER FOR AIR QUALITY AND ENVIRONMENTAL HEALTH-RELATED COMPLAINTS

34 EMPR ANNEXURE F INCIDENT REGISTER AND BASIC ACCIDENT REGISTER TEMPLATES

35 INCIDENT REGISTER (EXAMPLE) Incident means - an unexpected sudden occurrence, including a major emission, fire or explosion leading to serious danger to the public or potentially serious pollution of or detriment to the environment, whether immediate or delayed Date Incident Comments Corrective Action Taken Reference no. for Signature (yyyy/mm/dd) (Include any possible explanations for current condition and possible responsible parties. Include photographs, records etc. if available) (Give details and attach documentation as far as possible) On-Site Logbook (e.g. Rv 6/12 Inc 1)

36

37 BASIC ACCIDENT REGISTER (EXAMPLE) Date Accident Names of Persons Comments, Including Injuries Corrective Action Reference no. for OHS Signature (yyyy/mm/dd) Involved Sustained Taken Documentation and (Include any possible explanations for current accident. Include photographs, records etc. if available) (Give details and attach documentation as far as possible) Attachments (e.g. Rv 6/12 Acc 1)

38

39

40 SHE MANAGEMENT SYSTEM OHSAS STANDARD COMPANY PROCEDURE FOR EMERGENCY PREPAREDNESS AND CONTROL DOCUMENT NUMBER MET DATE OF ISSUE 01 March 2016 All rights reserved. No part of this document may be reproduced, translated, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without the written approval of Metal Concentrators (Pty) Ltd. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

41 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 REVISION RECORD SHEET Rev No Rev Date Description of Revision Originator 0A 01/03/2016 First Issue for Review Rayten Site Manager MD DATE OF NEXT REVIEW March 2018 or as required THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

42 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 INDEX OF CONTENTS REVISION RECORD SHEET PURPOSE SCOPE REFERENCES DEFINITIONS Site SHE Manager Site Manager RESPONSIBILITIES Site Manager Safety Officer Discipline Supervisors Emergency Team Employees PROCEDURE General Emergency Preparedness and Control An emergency on site can be: Procedure Points to remember during a Fire: Points to Remember during Evacuation: Re-Occupation of Building Fire Fighting and Training Fire Extinguishers Maintenance Damaged Equipment High Fire Risk Areas Fire Prevention Fire Drills Emergency Procedure Review RECORDS APPENDICES... 9 THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

43 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of PURPOSE The purpose of this procedure is to define the requirements for emergency preparedness and control. 2.0 SCOPE This procedure applies to all Metal Concentrators (Pty) Ltd. Note 1: No customisation or modifications shall be allowed unless approved by the SHE Manager. 3.0 REFERENCES Fire Protection and Emergency Equipment Procedure Medical Treatment Incident Investigation and Preventative Action Occupational Health and Safety Act 85 of 1993, GNR 1031 of 1996 (General Safety Regulations), Section 3: First Aid, Emergency Equipment and Procedures Occupational Health and Safety Act 85 of 1993, GNR 1010 of 2003 (Construction Regulation), Section 27: Fire Precautions on Constriction Sites Mine Health and Safety Act 29 of 1996, GNR 93 of 1997 (Regulations) Chapter 5: Fires and Explosions Mine Health and Safety Act 29 of 1996, GNR 93 of 1997 (Regulations) Chapter 16: Rescue, First Aid and Emergency Preparedness and Response Mine Health and Safety Act29 of 1996, GNR 992 of 1970 (Mines and Works Regulations) Chapter 24: First Aid and Recue Brigades Compensation for Occupational Injuries and Diseases Act 130 of 1993 (COID) OHSAS 18001:2007 Clause The latest revision of all referenced documents shall apply. 4.0 DEFINITIONS 4.1 Site For the purpose of this procedure Site shall mean Metal Concentrators (Pty) Ltd. operational sites. 4.2 SHE Manager Means either the Corporate SHE Manager or Site Specific SHE Manager, pending on the relevant appointment. 4.3 Site Manager Means the appointed Site Manager or the Facility Co-ordinator. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

44 5.0 RESPONSIBILITIES 5.1 Site Manager EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 Ensure that site specific emergency preparedness and control procedure are implemented and regular drills are held. 5.2 Safety Officer The Site Safety Officer shall be replaced with the site SHE Manager, pending on the structure and appointment of the site. Shall ensure the site specific emergency preparedness procedure is also indicated in pictograph form, regular drills arranged and records kept. 5.3 Discipline Supervisors To ensure that all employees know the emergency signal (sound), nearest exit and assembly point, and participate and comply with drills. 5.4 Emergency Team The Emergency Team (First Aiders, Fire Fighters, Evacuation Co-ordinator and Evacuation Wardens) shall know their emergency siren (sound), nearest emergency exit and assembly point. 5.5 Employees Employees shall know their emergency siren (sound), nearest emergency exit and assembly point. 6.0 PROCEDURE 6.1 General Emergency Preparedness and Control All SHE inductions shall include the emergency response plan for the particular site. Existing and new employees shall be subjected to safety induction. Records of induction attendance shall be kept on file. Be prepared. Train and appoint competent employees to deal with emergencies. The site shall establish and implement an emergency preparedness and control plan based on the risk assessment of identified potential emergency scenarios. The emergency plan shall address the types of emergencies and the nature of the response shall include emergency response equipment, training and drills. The emergency team shall ensure that in the event of an emergency all employees leave the site at the sound of the emergency siren and proceed to a safe area demarcated for the purpose. The safe area shall be demarcated and the relevant Assembly Point sign displayed. An evacuation route diagram shall be visibly displayed at strategic points. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

45 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 All employees, clients, visitors, contractors and suppliers shall be given awareness training and participate in regular evacuation drills (every (3) three months). 6.2 An emergency on site can be: A fire Injuries Vehicle accident including cranes Bomb threats/attacks/robberies Civil unrest (strikes/stay away etc) Floods Structure collapse Building collapse Falling structure from above A chemical spillage 6.3 Procedure Should an emergency occur in your work area, the following procedure shall be followed: Immediately inform any one of the following: Site Manager/SHE Manager Discipline Supervisor Safety Officer/SHE Representative Set off the alarm. If you are not in immediate danger, remain calm and await instructions. If you receive the order to evacuate the area, do it in an orderly fashion. Do not run. Report at the demarcated assembly point. Await instructions. If at all possible and you are a trained First Aider with a valid first aid certificate, render first aid to any injured persons or make the area safe without endangering yourself. A roll call shall be done by appointed employee/s. If all persons are not accounted for, he/she shall inform the Emergency Co-ordinator who shall make a decision to locate the missing person/s without endangering anybody else. After the emergency situation has been brought under control, the area shall be declared safe by the Emergency Co-ordinator. Only after the site has been declared safe may the employees return to their working areas. In the case of any fatalities, do not disturb or remove any evidence from the scene of the accident. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

46 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 GOLDEN RULE: STAY CALM DO NOT PANIC! REMEMBER THAT EVACUATION ORDERS SHALL ALWAYS BE GIVEN IN TIME. YOUR SAFETY IS TOP PRIORITY. 6.4 Points to remember during a Fire: Close windows and doors. Await evacuation orders. Do not leave without instruction from the Evacuation Warden and follow him/her to assembly point. Follow prescribed escape routes. Remember personal belongings, do not go back to re-claim any personal belongings. At assembly point, stay in one group and stay calm, do not leave the assembly point. 6.5 Points to Remember during Evacuation: Employees are responsible for clients, visitors, contractors and suppliers. Do not go back to reclaim personal belongings left behind. If you are the Site Manager, can you account for all your people (including client, visitors, contractors and suppliers? 6.6 Re-Occupation of Building Use as many entrances as possible. Do not gather at one point. Handicapped employees are to enter the building last. Employees are responsible for clients, visitors, contractors and suppliers. 6.7 Fire Fighting and Training Fire team members shall be trained and appointed as per Construction Regulation 27(1) a sufficient number of workers are trained in the use of fire extinguishing equipment. It is the responsibility of the Contractor s Safety Officer to ensure that all employees involved in grinding, cutting or welding are familiar with fire fighting procedures and the use of fire fighting equipment. 6.8 Fire Extinguishers Dry Chemical Powder and Carbon Dioxide fire extinguishers are acceptable. Water may never be used on live electrical fires. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

47 EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of Maintenance All Fire Extinguishers shall be: Conspicuously numbered. Entered in a register. Visibly inspected monthly by a competent person. Serviced at least annually by an accredited supplier. Inspection records entered in the register and signed Damaged Equipment Fire extinguishers with damaged or broken seals are to be returned to an accredited supplier for re-charge / repair. Details shall be entered in the register High Fire Risk Areas Cognisance shall be taken of the fact that certain areas might be designated as High Fire Risk Areas on account of the large number of rubber-lined, polyurethane and fibreglass components, chemicals, gasses etc. present. As such, additional precautions have been instituted to ensure that strict control is exercised over all grinding, cutting and welding operations being carried out in these areas. In addition, fire-fighting equipment, fire alarms and activating mechanisms shall be increased Fire Prevention Good housekeeping plays a major role in fire prevention. All flammable / consumable materials shall be removed on a daily basis. The minimum amount of low flash point flammable liquids shall be brought onto site. All required safety signs shall be posted if any work is carried out with any flammable / consumable materials, i.e. NO SMOKING, NO NAKED FLAMES and NO UNAUTHORISED ENTRY. Supervisors are to do constant and regular inspections to ensure adherence of Procedures Fire Drills Fire drills shall be conducted every (3) three months. Fire drills can be planned or unplanned and shall entail complete evacuation of the site on the sound of the alarm. Evacuation results are to be recorded. Post mortem review meetings shall be held after every emergency drill to determine deviations/shortcomings and the corrective/preventative action to be taken Emergency Procedure Review Emergency procedure shall be reviewed after every drill and any actual emergency to determine relevancy, necessity and items requiring attention. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

48 7.0 RECORDS EMERGENCY PREPAREDNESS AND CONTROL PROCEDURE DOCUMENT NUMBER DATE PAGE MET March of 9 The following documents/records shall be generated and maintained as proof of the effective implementation of the above. a) Evacuation Routes/Plans b) Legal and Statutory Appointments c) Induction Training Records d) Evacuation Drill Record Form 8.0 APPENDICES Appendix 1 Incident Reporting and Communication Protocol Appendix 2 Record of Emergency Drill Appendix 3 Poison Treatment Card Appendix 4 Response Plan 1 - Fire Appendix 5 Response Plan 2 - Chemical Fire Appendix 6 Response Plan 3 - Chemical Spillage Appendix 7 Response Plan 4 - Injuries Appendix 8 Response Plan 5 - Vehicle Accident Appendix 9 Response Plan 6 - Bomb Threats/Attacks/Robberies Appendix 10 Response Plan 7 Strikes/Stay Away Appendix 11 Response Plan 8 - Floods Appendix 12 Response Plan 9 - Rescue at Heights Note: The Response Plans are guidelines only and shall be customised for specific site requirements where necessary. THIS PROCEDURE IS UNCONTROLLED ONCE PRINTED OR DOWNLOADED

49 RESPONSE PLAN 1 FIRE EXPLOSION DOCUMENT NUMBER DATE PAGE MET March of 4 Evacuate only when instructed by the Emergency Co-ordinator to leave or if your building is collapsing, filling with heavy smoke or flames, or if the evacuation siren (alarm) has sounded. The alarm shall be raised by the whistle with the super sound canister as the backup: (3 signals of 5 seconds each). On hearing the evacuation alarm DON T PANIC. Stop all machines, air conditioners, heater and log off computers. Lock safes. Place critical records in the fire-proof cabinets or safes OR take them with you. Shut off any gas or electrical power and air conditioners. Close doors and windows. Open doors and all area windows, if bomb in building. Take personal belongings. Reduce fall potential by removing high-heeled or similar footwear. Take responsibility of the safety of the clients, visitors, contractors and suppliers. Leave the building through the nearest exit. Don t run (this causes panic) Don t shout (this causes panic) Don t push past others (this causes panic and people may fall) Use stair handrails. Don t stop or return to fetch personal items. Assist medical cases or disabled people where you can. Go to your assembly point for roll call and wait for further instructions. Supervisors are responsible to take the roll call for each of their responsible areas. Hr is responsible to take the roll call for the office employees. Keep and stay away from any risk areas. Don t go back to the building until the Emergency Co-ordinator declare the area safe. No employee is permitted to communicate to any external parties (ie clients, media, government officials/organisations etc). The emergency communication protocol is to be strictly adhered to. AT ALL TIMES: Don t Panic Remain Calm Don t leave a medical case or injured person unattended. Keep away from the emergency area. Follow instructions. Don t make unnecessary phone calls. Don t spread rumours.

50 RESPONSE PLAN 1 FIRE EXPLOSION DOCUMENT NUMBER DATE PAGE MET March of 4 DUTIES OF THE EMERGENCY CO-ORDINATOR On receiving the emergency alarm/signal, take immediate control of the situation and direct all actions. The priority is to protect life, then property and then minimise loss damage. Notify the Emergency Team immediately and direct their activities. Communicate the emergency situation immediately to the Site Manager/Managing Director/Director. The Site Manager/Managing Director/Director (in the absence the Safety Officer or Emergency Coordinator) shall communicate the emergency situation to the relevant General Manager or Managing Director. Establish the risk to life and property. Receive and evaluate the information. Maintain status list, showing each area of the premises and record the current status of each area. If necessary, order the shutdown of the emergency area. Advise and maintain contact with Senior Management. Complete a diary of events. Where possible, ask someone to record events and damage (i.e. video/photos etc). When deemed safe, have employees resume normal duties. Perform a de-brief of the emergency situation and events with the Emergency Team. Keep all records for investigations and reporting to the external authorities, insurers, etc. Refrain from spreading rumours and communicating to external parties, i.e. clients, media and government organisations and or officials. DUTIES OF THE EMERGENCY EVACUATION WARDEN Communicate the evacuation by using whistle (the super sound canister is a back-up) placed at the first aid boxes on the premises (3 signals at 5 second each) as well as by word of mouth reassure to avoid panic. Report the emergency situation to the Emergency Co-ordinator (in the absence to the Site Manager or Safety Officer). Wait for further instructions. In the case of an external threat (ie bomb or attack), evacuate people to your nearest safe route. People to take cover by lying face down. Emerge from cover only when instructed to do so or after the situation has stabilised. Render and offer first aid assistance where you can. Don t touch or remove any objects as you could destroy valuable evidence. On instructions, instruct all people to evacuate in an orderly manner, no pushing, running etc, but to walk briskly to the emergency exit and gather at the designated assembly point. Where equipment is involved, first check if it s safe to stop or switch if off to prevent further injury or loss. Ensure evacuation is orderly and be aware of the needs of the disabled, clients, visitors, contractors and suppliers.

51 RESPONSE PLAN 1 FIRE EXPLOSION DOCUMENT NUMBER DATE PAGE MET March of 4 Ensure that all people, other than the Emergency Team, leave the area. Cordon off the area and post guards in safe locations to prevent unauthorised entry to the building. Don t interfere with anything at the emergency scene. Stay in touch with the Emergency Co-ordinator (in the absence to the Site Manager or Safety Officer) and keep the Emergency Controller informed on status and development. Call for First Aiders and render first aid where necessary. Supervisors to take nominal roll call at the assembly point to make sure all are accounted for. Take nominal roll call for all office employees at the assembly point to make sure all are accounted for. Security to take nominal roll call for all visitors (clients, contractors, suppliers etc) at the assembly point to make sure all are accounted for. Report roll call missing people to the Emergency Co-ordinator. Maintain control at the assembly point and wait for further instructions. Take notes of the emergency situation for later investigation purposes. Refrain from spreading rumours and communicating to external parties, ie clients, media and government organisations and or officials. DUTIES OF THE FIRST AIDER Proceed to the emergency area if requested or the alarm is sounded. Take your First Aid box. Follow area entry instructions from the Emergency Co-ordinator or first make sure it s safe to enter. Assess the extent of the emergency and whether you need to apply a triage plan for multiple injuries. Render first aid treatment (wearing gloves). Move stabilised injured to exits. Arrange for professional medical assistance to be called. Extricate trapped persons, if possible. Don t leave injured unaccompanied, unless your life is in danger. Assist professional medical staff, as requested. Assist with portage and casualty dispatch. Make sure medical waste is properly handled and disposed of. Make sure your first aid equipment is replaced. Make sure the necessary WCL2 forms are completed for the dispatch of the injured.

52 RESPONSE PLAN 1 FIRE EXPLOSION DOCUMENT NUMBER DATE PAGE MET March of 4 DUTIES OF THE FIRE FIGHTER Ensure all the fire equipment is operational and available for an emergency. Check the entire emergency exit routes and that they are unlocked and accessible for evacuation. Make sure that all the emergency exit routes are free of any obstructions and that there are no suspicious objects along the exit routes. Proceed to the emergency area if requested or the alarm is sounded. Follow area entry instructions from the Emergency Co-ordinator or first make sure it s safe to enter. Do not risk your own life. Direct any fire fighting as necessary. Make sure all doors and windows are closed and all electricity, except for lights, is switched off. Make sure air conditioning, air gas and fuel pipelines are switched off. Account for and rescue. Assist the Evacuation Warden during the evacuation. Stop people re-entering the building, making sure you are in a safe position. Inform the Emergency Co-ordinator of fire status and developments. Request assistance as required through the Emergency Co-ordinator. Hand over the fire fighting duties to the fire department on arrival and provide support and fire information to the fire officer in charge. Direct employees not required for specific duties to evacuate. Advise the Emergency Co-ordinator when it is safe for people to re-enter the building. Make sure the fire equipment is sent for recharge and properly replaced on site. FOR YOUR SAFETY Know where all the fire equipment is located in your area. Know how to operate all the fire equipment. Know who in your area is fire trained, to help you.

53 RESPONSE PLAN 2 CHEMICAL FIRE EMERGENCY DOCUMENT NUMBER DATE PAGE MET March of 2 During Normal Working Hours 1. Raise the Emergency Alarm IF POSSIBLE RELAY INFORMATION ON TYPE OF CHEMICAL FIRE 2. Everyone hearing the emergency alarm to report at the assembly point. 3. Report the details to the SHE Manager (in the absence of a SHE Manager, Managing Director or any Director in the office). Do a roll-call of all persons on the premises. Dispatch rescue teams, if necessary. Consult MSDS file for fire fighting tips and dispatch fire fighters with breathing apparatus. Report Manager 4. Shut down all operations Remove vehicles located near the fire. 5. Safety Officer to notify RECEPTION to contact emergency personnel and related authorities about the situation. Contact Emergency Team

54 RESPONSE PLAN 2 CHEMICAL FIRE EMERGENCY DOCUMENT NUMBER DATE PAGE MET March of 2 6. Follow instructions of the Emergency Co-ordinator/Safety Officer Listen Up 7. Emergency Service personnel to take control over the situation upon arrival. 8. Complete all relevant incident/investigation documentation and reports. Fill in ADDIONAL EMERGENCY NUMBERS: SAPS NATIONAL EMS CELL 112 TELKOM 1022 NETCARE ER FIRE DEPARTMENT 999

55 RESPONSE PLAN 3 CHEMICAL SPILLAGE DOCUMENT NUMBER DATE PAGE MET March of 1 1. Stop any further distribution or flow of chemical product 2. Report the details of the spillage to the Safety Officer type of chemical, volume, etc. Report Manager 3. Barricade the affected area. Consult the MSDS on how to handle the spill. Use spill kit for small spill 4. For large and possibly uncontained spills consult with a Hazardous Chemical specialist on safe cleanup and disposal. INVICO Complete all relevant incident/investigation documentation and reports Fill in

56 RESPONSE PLAN 4 INJURIES DOCUMENT NUMBER DATE PAGE MET March of 1 1. Stop activities currently in progress. 2. Report to the First Aider/Reception. Reception to contact the First Aider if necessary. 3. The First Aider to take control over situation. Assistance may be obtained, however the First Aider will remain in control until the arrival of emergency services if necessary. REPORT 4. If injured person must be moved to a Doctor or Hospital, First Aider or HOD to accompany him/her. WCL 2 forms to be completed and a copy to accompany injured. ER Netcare First Aider to report the incident to the SHE Manager (in the absence to the Managing Director or any Director at the office. 6. Complete all relevant incident/investigation documentation and reports.

57 RESPONSE PLAN 5 VEHICLE ACCIDENT DOCUMENT NUMBER DATE PAGE MET March of 1 1. Notify the SHE Manager and Head of Department/Site Manager immediately of the accident and relay all information on hand. Find out if emergency services were notified. What happened? Manager 2. SHE Manager shall immediately take action. If the SHE Manager cannot go the scene of the accident he shall dispatch a nominated senior employee to the scene with the WCL2 form in case of an injury. Photos and sketches of the scene must be made. 3. The driver must report the accident to the nearest Police Station the same day of the accident. The driver must obtain a Police Case Number and a copy of his/her affidavit at his/her earliest convenience and submit to the Pool Vehicle Administrator/Site Manager. 4. Motor accident claim form to be completed Fill In 5. Complete Accident/incident report. Fill In 6. Conduct a thorough investigation to determine basic cause and put preventative measures in place. Why did the accident happen? What can be done to prevent it from happening again?

58 RESPONSE PLAN 6 BOMB THREATS/ATTACKS DOCUMENT NUMBER DATE PAGE MET March of 5 Part A Coming Across the Bomb 1. Raise the Emergency Alarm 2. Everyone hearing the emergency alarm to report at the assembly point in front of the reception area. Account for all persons on the plant. 3. Emergency Co-ordinator to take full control of the situation, or his delegate in his absence Listen 4. Inform the Bomb Squad Bomb Squad Please! SAPS SAPS to disarm the bomb and investigate and inspect all areas on the plant and declare it safe before any person is allowed back on the premises.

59 RESPONSE PLAN 6 BOMB THREATS/ATTACKS DOCUMENT NUMBER DATE PAGE MET March of 5 Part B Someone Calling Bomb Threat 1. Inform a Director immediately that a bomb threat is being made There is bomb threat 2. Raise the alarm and to contact the nearest Police Station Call the Police Police Please! 3. The person receiving the call must ask for the location of the bomb and keep the caller on the line as long as possible Let me be calm 5. Move to assembly point without touching any suspect items 6. Evacuate on instruction, vehicles on site must not be move Lets move to a safe area 7. SAPS to investigate and inspect all areas on the plant and declare it safe before any person is allowed back on the plant.

60 RESPONSE PLAN 6 BOMB THREATS/ATTACKS DOCUMENT NUMBER DATE PAGE MET March of 5 Part C Attack (Armed Robbery) Remember: If the robber demands cash or property, give it up! It's not worth injury or death. No one likes to think about becoming a victim of an armed robbery. However, the time to think about a robbery is before it happens. Crimes against business are usually crimes of opportunity. If you make it easy for someone to target the company for a robbery, chances are someone will. So don't make it easy. Make it risky and unrewarding. What to do during an armed robbery SECURITY Try to stay calm. Don't make any sudden movements to upset the robber. Do exactly as you are told. DO NOT RESIST! Activate your panic button ONLY if you can do so secretly. Tell the robber about anything that might surprise him, such as someone who is expected to arrive soon. If you have to move or reach, tell the robber what you are going to do and why. Inform the robber that you have to contact reception for them to open the internal gates as you cannot do it from your side. Try to get a good look at the robber so you can describe him later. Don't be a hero. Give the robber time to leave. Note his direction of travel when he leaves. Try to get a description of the vehicle ONLY if you can do so without exposing yourself to harm. What to do after an armed robbery Call the police immediately, even if you have already activated the alarm. Do not discuss the details of the robbery with witnesses or fellow employees. Ask any witnesses to stay until police arrive. If they can't, get their names, phone numbers and addresses. Do not touch anything that the robber may have touched. Block off areas where the robber was, if necessary.

61 RESPONSE PLAN 6 BOMB THREATS/ATTACKS DOCUMENT NUMBER DATE PAGE MET March of 5 Try to recall as much as you can about the robber's appearance, speech and mannerisms. Make notes. Let the police answer inquiries from the news or media. RECEPTION Always look at the security cameras when informed by security about a visitor. Should it be noted that an armed robbery is in progress, do not open the internal security gates. Activate your panic button. Should it happen that the robbers successfully breached the security at the gate and is standing in front of you follow this procedure: Try to stay calm. Don't make any sudden movements to upset the robber. Do exactly as you are told. DO NOT RESIST! Activate your panic button ONLY if you can do so secretly. Tell the robber about anything that might surprise him, such as someone who is expected to arrive soon. If you have to move or reach, tell the robber what you are going to do and why. Inform the robber that you cannot open the gate from your side, show this if you have to. Contact Site Manager and inform him that you have no authorization to open the gate to the admin offices, this will be the pass code to use this is true, Site Manager is aware of this and will know that something is wrong and activate the panic from his side. Should Site Manager not be available contact the second person in charge. Try to get a good look at the robber so you can describe him later. Don't be a hero. Give the robber time to leave. Note his direction of travel when he leaves. Try to get a description of the vehicle ONLY if you can do so without exposing yourself to harm. MANAGEMENT Should a call be received from reception informing you that she does not have access to the gate going to admin you should immediately activate the panic button, do not question her, accept the fact that a robbery might be in progress, rather a false alarm than no alarm at all. Contact the staff at the vaults and have the lock such immediately.

62 RESPONSE PLAN 6 BOMB THREATS/ATTACKS DOCUMENT NUMBER DATE PAGE MET March of 5 Try to stay calm. Don't make any sudden movements to upset the robber. Do exactly as you are told. DO NOT RESIST! Tell the robber about anything that might surprise him, such as someone who is expected to arrive soon. If you have to move or reach, tell the robber what you are going to do and why. Try to get a good look at the robber so you can describe him later. Don't be a hero. Give the robber time to leave. Note his direction of travel when he leaves. Try to get a description of the vehicle ONLY if you can do so without exposing yourself to harm.

63 RESPONSE PLAN 7 STRIKES/STAY AWAY DOCUMENT NUMBER DATE PAGE MET March of 1 1. The Site Manager and or SHE Manager will inform the MD of any planned industrial action that will take place. The MD shall evaluate how the site operation will be affected and shall plan accordingly. How Do I deal with this? 2. Communicate planned industrial action with the Clients and relevant interested and affected parties. How do we deal with it? 3. Security and emergency team/s to be informed to be on high alert. Emergency Support Please! 4. Establish emergency teams availability. Who will be available? 5. On the day of the strike, all persons that are joining the strike will not be allowed on the Premises. Security to allow only non striking personnel onto Premises. Security measures must be stepped up for unauthorized entry to the premises. 6. If the strike turns violent call the local police and or security services for assistance. Police please! WHY? 7. If necessary shut down operation and vacate premises. 8. Keep MD informed. 9. Post strike analysis must be performed

64 RESPONSE PLAN 8 - FLOODS DOCUMENT NUMBER DATE PAGE MET March of 1 1. Remove vehicles to higher areas 2. Remove all documents and files to a safe place 3. Disconnect the electricity. Shut off all operational equipment 4. Maintain contact with Emergency Services and Fire Department Emergency Services 5. Ensure the safety of all employees evacuate in time 6. Notify MD MD

65 RESPONSE PLAN 9 RESCUE AT HEIGHTS DOCUMENT NUMBER DATE PAGE MET March of 2 1. The buddy shall raise alarm and start the rescue process. REPORT 2. The Safety Officer/Emergency Co-ordinator shall dispatch other trained personnel to the specific work area. The Safety Officer/Emergency Co-ordinator shall call external emergency personnel to assist. Contact Emergency Personnel 3. Stay in contact with person, make sure he is in an upright position (thighs horizontal) and ensure proper airway, breathing and blood circulation (ABC). Keep patient calm to reduce shock 4. Once the patient is on ground level keep the patient in a seated position for at least 30 minutes (if conscious), if unconscious lay him down to perform CPR 5. Report to paramedic personnel of possible suspension trauma, blood pooling in legs or refill syndrome. Dispatch employee to Hospital for observation, if the paramedics decide upon it. Safety Officer and First Aider to accompany him/her. W.CL 2 forms to be completed and a copy to accompany injured. ER Netcare SAPS