incident procedure and reporting form

7/29/2019 Incident Procedure and Reporting Form

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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

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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 INVESTIGATINGENVIRONMENTAL 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 incidenttook 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 thequarterly 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 System

Identified

Problem

Incident

Report

Immediate

Corrective

Action

Initiator

IRRoot cause

investigation

ACTION

ACTION

ACTION

Determine:

Validity

Preventive

Action

Responsibility

Time frame

RME Check up

NotV

alid

Determineeffectiveness of

preventive action

aftera period of

time

Effective

YES

NOFeedback

GOOD YESNO

Comp

leteI

ncident

Repo

rt

Dec

ideon

imme

diate

actio

nto

betake

n

Take

actio

n

Env Impact

of Actions

Corrective & Preventive Action

Take

Furthe

rAction

SAFETY

OFFICER

Update

on

Database

Update

on

Database

Ifhigh

risk,

repo

rt

immed

iately

toRME

Date: 9 July 2001 (uncontrolled copy)

Ref no.: BRPMir.v 1.1

Close

Incident

Report

High Risk Incidents:

any incident which derive

from a significant aspect

and have the potential

to 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

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3. RME VISITS SITE OF INCIDENT

INCIDENT DESCRIPTION:

......

DESCRIPTION OF RECEIVING ENVIRONMENT:

......(Attach photos 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 INATTACHMENT 1

DESCRIPTION OF IMPACT ON AIR:

...

Extent(a)

Duration(b)

Severity(c )

Consequence(a+b+c)

Probability(d)

Significance(a+b+c) x d

Correctiveaction required

AAplcLevel 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/globalScale: 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)

permanentScale: 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 givesthe 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 theconsequence:

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 Officeand to the relevant Government Departments.

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ATTACHMENT 2:

APPLICABLE DEFINITIONS:

Aspect: An environmental aspect refers to an element of anorganisations activity, product or service that can have abeneficial or adverse impact on the environment.

Impact: An impact refers to the change that takes place in theenvironment as a result of the aspect.

Environment:Surroundings in which an organisation operates, includingair, water, land, natural resources, flora, fauna, humansand their interrelation.(The above three definitions are adopted from the SABSISO 14001-standard).

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ATTACHMENT 3:

Environmental Incidents and Complaints as per AAplc

ParameterDefinitions

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-termimpairment of ecosystem function or surface/ground waterresource; AND/OR

an inconvenience/disturbance/disruption/annoyance

(including odour, dust, noise, traffic problem, loss of watersupply) of short duration and with no long-term effect onthe community; AND/OR

a release of material (gas, liquid, solid) or energy whichhas the potential to cause illness, injury or propertydamage to the public, or one which causes short-termdiscomfort or reversible health effect to the public; AND/OR

minor repairable damage to commonplace structures ofcultural significance, or minor infringement of culturalvalues; AND/OR

isolated public complaints


a moderate impact on the physical or biologicalenvironment (air, land, water or habitats) with limitedimpairment of ecosystem function or surface/ground waterresource; AND/OR

a minor impact to fauna or flora in a statutory designatedarea (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 onthe community; AND/OR

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

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

attention from local media or widespread complaints

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a significant impact on the physical or biologicalenvironment (air, land, water or habitats) with extensive or

long-term impairment of ecosystem function orsurface/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 watersupply) of long duration or with long-term effect on thecommunity; AND/OR

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

irreparable damage to highly valued structures or sacredlocations; 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 ortheir servants, agents or contractors, (generally referred to as the Company), are notresponsible for any actions (or lack thereof) taken as a result of the informationcontained herein and the Company cannot be held liable for any damages resulting fromreliance on or use of this information. Without limiting the above, as contributors, theCompany 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 theinterests of sharing good practice. Whilst the information may be regarded as indicativeof good practice, and effort has been made to ensure that it is accurate, norepresentation 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 formaking their own assessments of the information. Users are accordingly advised toobtain independent advice before acting on the information contained herein, and to takespecific 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 kindwhatsoever (including consequential loss), suffered by any person acting in relianceupon the information, howsoever such loss or damage may have been caused orsustained. The Company expressly disclaims liability for any such loss or damage. Byaccessing the information presented on the terms and conditions indicated, the userhereby indemnifies and holds the Company harmless against all such loss or damage.

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