REPORT - International Cyanide Management Code · International freight forwarding and multimodal...

February 2011

INTERNATIONAL CYANIDE MANAGEMENT CODE CYANIDE TRANSPORTATION AUDIT

Pioneer Ocean Freight, Transport Certification Audit, Thailand, Summary Audit Report

Submitted to:International Cyanide Management Institute Pioneer Ocean Freight (ICMI) 10th floor, Green Tower 888 16th Street, NW-Suite 303 3656/30 Rama 4 Road Washington, DC 20006 Klong Toey, Bangkok 10110 UNITED STATES OF AMERICA THAILAND

REPO

RT

Report Number. 107643320-002-R-Rev1 Distribution:1 Copy – ICMI (+1 Electronic) 1 Copy – Pioneer Ocean Freight 1 Copy – Golder Associates Pty Ltd

PIONEER OCEAN FREIGHT, TRANSPORT CERTIFICATION AUDIT, SUMMARY AUDIT REPORT

February 2011 Report No. 107643320-002-R-Rev1

Record of Issue

Company Client Contact Version Date Issued Method of Delivery

ICMI Norm Greenwald 107643320 002 R Rev1 3 February 2011 Electronic and Hard Copies

Pioneer Chamlong Phuncharoensin 107643320 002 R Rev1 3 February 2011 Electronic


February 2011 Report No. 107643320-002-R-Rev1 i

Table of Contents

1.0 INTRODUCTION ........................................................................................................................................................ 1

1.1 Operational Information ................................................................................................................................ 1

1.2 Description of Operation ............................................................................................................................... 1

1.2.1 Pioneer Group of Companies .................................................................................................................. 1

1.2.2 Pioneer Ocean Freight ............................................................................................................................ 1

1.2.3 Sodium Cyanide Transportation .............................................................................................................. 2

1.2.4 Transit Storage ....................................................................................................................................... 2

1.3 Auditors Findings and Attestation ................................................................................................................. 3

2.0 PRINCIPLE 1 – TRANSPORT ................................................................................................................................... 4

2.1.1 Transport Practice 1.1 ............................................................................................................................. 4






PRINCIPLE 2 – INTERIM STORAGE ............................................................................................................................... 10

2.1.7 Transport Practice 2.1 ........................................................................................................................... 10

PRINCIPLE 3 – EMERGENCY RESPONSE .................................................................................................................... 11






APPENDICES APPENDIX A Limitations


Pioneer Ocean Freight 3 February 2011

Name of Facility Signature of Lead Auditor Date

February 2011 Report No. 107643320-002-R-Rev1 1

1.0 INTRODUCTION 1.1 Operational Information Name of Transportation Facility: Pioneer Ocean Freight

Name of Facility Owner: Pioneer Ocean Freight

Name of Facility Operator: Pioneer Ocean Freight

Name of Responsible Manager: Chamlong Phuncharoensin, General Manager, Pioneer Ocean Freight

Address: Pioneer Ocean Freight 10th floor, Green Tower, 3656/30 Rama 4 Road, Klong Toey, Bangkok 10110, THAILAND State/Province: Bangkok Country: Thailand

Telephone: +66 2 367 3655 68

Fax: +66 2 367 3651

E-Mail: [email protected]

1.2 Description of Operation 1.2.1 Pioneer Group of Companies PGC was founded in 1972 and today is now an international freight forwarder and multimodal transport operator. The PGC consists of several companies specialising in a range of services including (but not limited to) the following:

Air freight booking

Sea freight booking

Multimodal Transport operations

Packaging

any overs and

trailers each capable of carrying up to 28 tonnes. Pioneer specialises in:

Customs clearance

Warehousing

Inland transportation

Container haulage Services

1.2.2 Pioneer Ocean Freight Pioneer forms the Thailand transportation arm of PGC and has been established for 30 years. The compemploys approximately 200 staff including 35 drivers, and has a dedicated fleet of 40 prime m





Customs clearance

International freight forwarding and multimodal transport

Export documentation

Warehousing

00 tonnes per annum of cyanide from the Port of Laem

audit, Pioneer was actively engaged in the transportation of solid sodium cyanide along the

and

001 and delivery to Sepon commenced in 2003. Each deliver typically

Chabang Authority of Thailand (PAT), a government agency.

s

At no stage is cyanide removed from the trucks or containers prior to unloading at customer mine sites.

Packing, crating and unpacking

Inland transportation and container trucking

Air transportation and air courier services

Pioneer currently transports approximately 2,4Chabang to mine sites in Thailand and Laos.

1.2.3 Sodium Cyanide Transportation At the time of the following routes:

Port of Laem Chabang, Bangkok to the Chatree Mine, Thail

Port of Laem Chabang, Bangkok to the Sepon Mine, Laos

Delivery to Chatree commenced in 2consists of five containers monthly.

The solid cyanide delivered by Pioneer is manufactured and packaged into intermediate bulk containers (IBCs) within freight (shipping) containers by Orica Mining Chemicals (Orica) and Australian Gold Reagents (AGR). The containers are dispatched from Australia and are delivered by ship to the Port of Laemin Thailand. The Port is operated by the Port

1.2.4 Transit Storage Within the scope of this audit, there are no trans-shipping depots or interim storage sites, as defined in the audit protocol. Storage in transit does occur at the Port of Laem Chabang while formalities such as customclearance and carrier releases are performed. Once formalities are complete, the cyanide containers arecollected from the Port of Laem Chabang and delivered to Chatree Mine in Thailand and Sepon Mine in Laos.





1.3 Auditors Findings and Attestation in full compliance with

The International Pioneer Ocean Freight is: in substantial compliance with Cyanide Management

Code not in compliance with

Audit Company: Golder Associates

Audit Team Leader: Edward Clerk, CEnvP (112), RABQSA (020778)

Email: [email protected]

Name and Signatures of Other Auditors Name Position Signature Date

Edward Clerk Lead Auditor and Technical Specialist

3 February 2011

Julia Horgan Trainee Auditor 3 February 2011

Dates of Audit The Transport Certification Audit was undertaken within three days (six person-days) between 6 September 2010 and 9 September 2010.

I attest that I meet the criteria for knowledge, experience and conflict of interest for Code Verification Audit Team Leader, established by the International Cyanide Management Institute and that all members of the audit team meet the applicable criteria established by the International Cyanide Management Institute for Code Verification Auditors.

I attest that this Summary Audit Report accurately describes the findings of the verification audit. I further attest that the verification audit was conducted in a professional manner in accordance with the International Cyanide Management Code Verification Protocol for Cyanide Transportation Operations and using standard and accepted practices for health, safety and environmental audits.





2.0 PRINCIPLE 1 – TRANSPORT Transport Cyanide in a manner that minimises the potential for accidents and releases.

2.1.1 Transport Practice 1.1 Select cyanide transport routes to minimise the potential for accidents and releases.

in full compliance with

The operation is in substantial compliance with Transport Practice 1.1

not in compliance with

Summarise the basis for this Finding/Deficiencies Identified:

Pioneer is in FULL COMPLIANCE with Transport Practice 1.1 requiring cyanide transport routes to be selected to minimise the potential for accidents and releases.

Pioneer, in consultation with its suppliers has implemented a procedure to guide the selection of transport routes to minimise the potential for accidents and releases or the potential impacts of accidents and releases. The Procedure prompts the persons undertaking the survey to consider recording a number of hazards including but not limited to areas of population density, waterways, road construction and condition including pitch and grade. The route survey is undertaken by representative of Pioneer and the applicable transporting agency (as a minimum requirement).

Pioneer has developed procedures to evaluate the risks of selected cyanide transport routes and takes the measures necessary to manage these risks. Route risk assessments have been undertaken for the transport of cyanide to Chatree and to Sepon. Pioneer has implemented a process and procedure to periodically re-evaluate routes used for cyanide deliveries. This procedure notes that route assessments will be reviewed when there is a change to the route, regulatory authority impost, an incident occurs or, at a minimum, annually.

Pioneer has documented measures taken to address risks identified with the selected routes. All management measures identified in the route risk assessments are documented within the Emergency Response Plan (ERP) and Transport Management Plan (TMP).

Pioneer seeks input from stakeholders and applicable governmental agencies as necessary in the selection of routes and development of risk management measures.

Convoys are used as a means of managing the risks of the road conditions and responding to emergencies. Each convoy is escorted by two escort vehicles (front and rear) that transport the equipment necessary to manage anticipated emergency events. For consignments to Sepon, the convoy is met at the border (Savannakhet) and escorted by a mine site vehicle (containing two emergency responders) and a Laos police officer who travels within the Escort Supervisors vehicle.

In the event of an incident, primary emergency response is coordinated by Pioneer. The duties of primary responders include immediate notification to government authorities and medical facilities (as necessary). The Laos public responders do not have a direct role in incident management outside of their normal duties and Pioneer has consequently limited their consultation.

Pioneer contracts cyanide transportation to Nava Inland Transport (Nava) and Tongtransmission Company Limited (Tongtrans). Nava is contracted by Pioneer to transport cyanide to destinations within Thailand (Chatree Gold Mine) and Tongtrans is contracted by Pioneer to transport cyanide within Laos (Sepon Gold Mine).





Pioneer has implemented individual Service Level Agreements with Nava and Tongtrans which is signed off by the Pioneer General Manager. Included in the agreement is the requirement for, amongst other regulatory requirements, compliance with the Code.

Pioneer assesses the ongoing performance of its subcontractors in accordance with the Pioneer Ocean Freight Subcontractor Management Procedure. This procedure requires subcontractors to be assessed at a minimum of every two years using a Pioneer Ocean Freight - Carrier Assessment Questionnaire.

In addition to the formal contractual arrangements and assessments, ongoing performance of subcontractors is also managed through the convoy process. All convoy personnel, including subcontractors, are under the direct control of the Escort Supervisor who is a Pioneer employee.

2.1.2 Transport Practice 1.2 Ensure that personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment.





Pioneer is in FULL COMPLIANCE with Transport Practice 1.2 requiring that personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment.

Pioneer ensures Nava and Tongtrans only use trained and competent operators to drive its trucks. Both Nava and Tongtrans have a list of dedicated drivers that have appropriate training and vehicle licences to transport cyanide. The Drivers detailed on the list cannot be amended without authorisation from Pioneer.

Nava and Tongtrans Transport Supervisors are responsible to check the licence currency of all drivers on a monthly basis. Additional checks are conducted by the Pioneer Escort Supervisor as part of the convoy pre-departure check on the validity of licences prior to departure.

Thailand and Laos are both members of ASEAN and drivers’ licences issued in Thailand are valid in other ASEAN member countries. Police also carry out regular checks of licenses along the routes.

All personnel operating cyanide transport equipment have been trained to perform their jobs in a manner that minimises the potential for cyanide releases and exposures. The training programme developed by Pioneer includes mandatory training for all staff involved in cyanide transportation.

Pioneer has implemented individual Service Level Agreements with Nava and Tongtrans, which is signed off by the Pioneer General Manager. Included in the agreement is the requirement for, amongst other regulatory requirements, compliance with the Code.





2.1.3 Transport Practice 1.3 Ensure that transport equipment is suitable for the cyanide shipment.





Pioneer is in FULL COMPLIANCE with Transport Practice 1.3 requiring that transport equipment is suitable for cyanide shipment.

Pioneer ensures Nava and Tongtrans only use equipment designed and maintained to operate within the loads it will be handling when transporting cyanide.

Both Nava and Tongtrans each have six prime movers and semi-trailers dedicated for cyanide transportation. A review of the equipment specifications confirmed they are designed to transport a full container of cyanide and the configuration allows a maximum gross weight of 45 tonnes within ASEAN member countries. The combined weight of the prime movers, trailers and a single 20 foot container is within the load limit.

Tongtrans and Nava maintain their fleet of trucks in accordance with the servicing frequency specified within the respective maintenance manuals for Volvo and Nissan.

There are several checks and inspections in addition to scheduled services as outlined below:

Both Tongtrans and Nava perform a safety check of the prime mover and trailer on the day prior to a planned convoy

The General Manager advised that the vehicles must pass the inspection before being released for the convoy

The Escort Supervisor also conducts an inspection of all vehicles prior to departure. This inspection is recorded on the Pre-Departure Vehicle Checklist, which is found in Appendix G of the Transport Management Plan

On an annual basis, vehicles are also required to be inspected by a third party prior to the vehicle’s registration being renewed

Pioneer has a developed procedure for the carriage of cyanide, which details the minimum equipment specifications for the transport of cyanide. The procedure prevents overloading of transport vehicles being used for handling cyanide.






2.1.4 Transport Practice 1.4 Develop and implement a safety program for transport of cyanide.





Pioneer is in FULL COMPLIANCE with Transport Practice 1.4 requiring the operation develop and implement a safety programme for transport of cyanide. Pioneer has procedures to ensure that the cyanide is transported in a manner that maintains the integrity of the producer’s packaging. These comprise checks by the Escort Supervisor, Drivers and Mine site representatives at the Port, along the route, border crossings and checks and the mine site prior to unloading.

Customs officials check the presence of seals and cross check the seal number against the container number listed on the delivery documentation.

Placards are used to identify the shipment as cyanide, as required by international standards. Procedures note any container of cyanide must be provided with a label of identification.

Pioneer has implemented a safety programme for cyanide transport that includes:

Vehicle inspections

Preventative maintenance

Limitations on operator or drivers’ hours

modify or suspend transport if conditions such as severe weather or civil unrest are encountered

gned off reement is the requirement for, amongst other

regulatory requirements, compliance with the Code.

Procedures to prevent loads from shifting

Procedures to

Drug abuse prevention

Pioneer has implemented individual Service Level Agreements with Nava and Tongtrans, which is siby the Pioneer General Manager. Included in the ag





2.1.5 Transport Practice 1.5 Follow international standards for transportation of cyanide by sea and air.





Transport Practice 1.5 requiring the operation to follow international standards for transportation of cyanide by sea and air is NOT APPLICABLE to Pioneer.

Pioneer does not transport consignments of cyanide by sea or air within the scope of this audit.

2.1.6 Transport Practice 1.6 Track cyanide shipments to prevent losses during transport.





Pioneer is in FULL COMPLIANCE with Transport Practice 1.6 requiring the operation track cyanide shipments to prevent losses during transport.

Transport vehicles have means to communicate with Pioneer, the mining operation, the cyanide producer and emergency responders.

The following communication equipment is used by the convoy:

Trucks – cell phone and radios

Convoy escort vehicle - cell phone and radio

Two way radios are used for internal convoy communication. The Escort Supervisor uses the cell phone to communicate with external responders and Pioneer.

Communication with the supplier and mine site is via email or telephone from the Pioneer General Manager.

Prior to the departure of the convoy, all communication equipment is tested. Prior to leaving the Port, the mine sites are pre-notified of the convoy details, route to be followed and ETA at mine site. If for some reason the convoy needs to be stopped or the ETA is delayed the Escort Supervisor notifies the Pioneer General Manager who then notifies the mine site. The Pioneer General Manager advised that a cellular network exists along the current routes. Different cellular network companies in Thailand and Laos result in the requirement to switch SIM cards within the phones.

At the border point of Savannakhet in Laos, the Escort Supervisor ensures all drivers change their SIM cards to the Laos communication system. No communication black out zones have been identified on routes to Chatree or Sepon.





Pioneer tracks the progress of cyanide shipments though regular reporting along the routes. Call up points for each route is specified within the TMP.

Pioneer implements chain of custody procedures to prevent loss of cyanide during shipment. The Escort Supervisor checks the Bill of Lading against the container numbers and seal numbers to verify the correct containers are loaded on the trucks. Customs officials also check the presence of seals and cross check the seal number against the container number listed on the Bill of Lading.

Shipping records indicating the amount of cyanide in transit and Material Safety Data Sheets are available during transport.

Once delivered, a mine site representative signs the Pre-departure Checklist confirming the consignment was received in good condition and unopened.

Pioneer has implemented individual Service Level Agreements with Nava and Tongtrans, which is signed off by the Pioneer Ocean Freight General Manager of Pioneer. Included in the agreement is the requirement for, amongst other regulatory requirements, compliance with the Code.





PRINCIPLE 2 – INTERIM STORAGE Design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent release and exposures.

2.1.7 Transport Practice 2.1 Store cyanide in a manner that minimises the potential for accidental releases.





Transport Practice 2.1 requiring transporters design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent release and exposures is NOT APPLICABLE to Pioneer. Within the scope of this audit, there are no trans-shipping depots or interim storage sites, as defined in the audit protocol. Storage in transit does occur at the Port of Laem Chabang but this is not the responsibility of Pioneer. At no stage is cyanide removed from the trucks or containers prior to unloading at customer mine sites.





PRINCIPLE 3 – EMERGENCY RESPONSE Protect communities and the environment through the development of emergency response strategies and capabilities

2.1.8 Transport Practice 3.1 Prepare detailed Emergency Response Plans for potential cyanide releases.





Pioneer is in FULL COMPLIANCE with Transport Practice 3.1 requiring the operation prepare detailed Emergency Response Plans for potential cyanide releases. Pioneer has developed an ERP to cover emergency response for potential cyanide releases within Thailand and Laos. The ERP is based on road transportation from the Port of Laem Chabang to Chatree mine site in Thailand and Sepon mine site in Laos. The plans are appropriate for the selected transportation routes and they consider relevant aspects of the transport infrastructure. The route evaluation process, route hazard/risk assessment process, and operational experience were used to identify ten likely emergency scenarios:

Dry Sodium Cyanide Spill – Inside Building/Storage Facility

Dry Sodium cyanide Spill – Outside Building/Storage Facility

Dry Sodium Cyanide Spill – Inside a Shipping Container

Shipping Container Decontamination

a Waterway

of Stored Cyanide

s

s in emergency response are identified in the documents and are aware of their roles in an emergency.

Vehicular Accident

Handling Wet Sodium Cyanide

Sodium Cyanide Spill to

Spill to Surface Water

Response to a Fire in the Vicinity

Roll-over of Shipping Container

The plan considers the physical and chemical form of cyanide and design of the transport vehicle as well aall aspects of the transport infrastructure. Storage facility emergency response plans were not developed, as cyanide is not stored at an interim storage facility between the Port of Laem Chabang and the mine site destinations. The emergency documentation includes descriptions of response actions, as appropriate for the ten anticipated emergency situations. External responders who have specific role





2.1.9 Transport Practice 3.2 Designate appropriate response personnel and commit necessary resources for emergency response.





Pioneer is in FULL COMPLIANCE with Transport Practice 3.2 requiring they designate appropriate response personnel and commit necessary resources for emergency response.

Pioneer has developed and implemented a training programme for its drivers and escort personnel. The training programme developed by Pioneer includes mandatory training for all staff involved in cyanide transportation. Pioneer also provides initial and periodic refresher training in emergency response procedures including implementation of the ERP.

Descriptions of the specific emergency response duties and responsibilities are detailed within the ERP. The ERP also includes ten emergency response guides to be followed in the event of an incident involving cyanide and the duties and responsibilities of key individuals. Pioneer has the necessary emergency response and health and safety equipment, including personal protective equipment during transport Pioneer maintains a list of all of the emergency response equipment that is available during the transport route. Section 6.5 contains a list of emergency equipment to be held at the transport contractors depots (checked monthly) and also a list of response equipment per convoy (checked prior to departure of every trip). These lists are focus on the serviceability of the equipment as well as its presence. Pioneer also has a Pre-Departure vehicle checklist which includes a check of the emergency response equipment. The checklist is completed by the Escort Supervisor prior to the departure of the convoy.


2.1.10 Transport Practice 3.3 Develop procedures for internal and external emergency notification and reporting.





Pioneer is in FULL COMPLIANCE with Transport Practice 3.3 requiring that they develop procedures for internal and external emergency notification and reporting.

The internal and external contact numbers are listed in the Emergency Contact List in the ERP, which is located in all trucks and escort vehicles.

The ERP contains a communications flow chart which outlines who to contact in an emergency. In addition to this, the 10 emergency scenarios prompt the reader to refer to the communications flow chart to contact the relevant parties.





The ERP contains procedures to ensure that internal and external emergency notification and reporting procedures are kept current. In addition to the formal review process, the Delivery Procedure Control Sheet requires the Escort Supervisor to note any observed changes in contacts and respective telephone numbers during each convoy.

2.1.11 Transport Practice 3.4 Develop procedures for remediation of releases that recognise the additional hazards of cyanide treatment.





Pioneer is in FULL COMPLIANCE with Transport Practice 3.4 requiring that they develop procedures for remediation of releases that recognise the additional hazards of cyanide treatment.

Pioneer has procedures for remediation, such as recovery or neutralisation of solutions or solids, decontamination of soils or other contaminated media and management and/or disposal of spill clean-up debris.

The ERP contains information on decontamination of a spill of solid or liquid cyanide into soil as well as information on the use of sodium hypochlorite for decontamination purposes.

The ERP prohibits the use of chemicals such as sodium hypochlorite, ferrous sulphate and hydrogen peroxide to treat cyanide that has been released into surface water.

Cyanide Awareness and mock drill training also contain information on spill remediation.

2.1.12 Transport Practice 3.5 Periodically evaluate response procedures and capabilities and revise them as needed.





Pioneer is in FULL COMPLIANCE with Transport Practice 3.5 requiring the operation periodically evaluate response procedures and capabilities and revise them as needed.

The ERP states the emergency response procedures are to be reviewed and evaluated following any incident that triggers implementation of the ERP. Recommendations arising from the investigation following an incident or training drills and audits are to be included in the ERP.

In addition to the formal review process, the Delivery Procedure Control Sheet requires the Escort Supervisor to note any end of delivery remarks, which may include observed changes in contacts and respective telephone numbers during each convoy. If a change in conditions are noted this is captured in Pioneer Procedure No. 2.

The ERP contains provisions for conducting mock drills. The training programme requires these drills to be conducted annually. Full scale incident scenarios involving external agencies such as mining companies,





police, fire service and a hospital or clinic are done every two years. Desktop drills were conducted in November 2009 and September 2010. A full scale practical exercise was undertaken in December 2010, with another planned for February 2011.


Report Signature Page

GOLDER ASSOCIATES PTY LTD

Ed Clerk ICMI Lead Auditor and Transport Technical Specialist

EWC/ST/arp

A.B.N. 64 006 107 857 Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation..

j:\env\2010\107643320 - orica cn transport audit bangkok\report\pioneer certification report\107643320-002-r-rev1 pinoneer sar.docx




APPENDIX A Limitations

LIMITATIONS

This Document has been provided by Golder Associates Pty Ltd (“Golder”) subject to the following limitations: This Document has been prepared for the particular purpose outlined in Golder’s proposal and no responsibility is accepted for the use of this Document, in whole or in part, in other contexts or for any other purpose. The scope and the period of Golder’s Services are as described in Golder’s proposal, and are subject to restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or circumstances that may exist at the site referenced in the Document. If a service is not expressly indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any determination has been made by Golder in regards to it. Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Document. Accordingly, additional studies and actions may be required. In addition, it is recognised that the passage of time affects the information and assessment provided in this Document. Golder’s opinions are based upon information that existed at the time of the production of the Document. It is understood that the Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations. Any assessments made in this Document are based on the conditions indicated from published sources and the investigation described. No warranty is included, either express or implied, that the actual conditions will conform exactly to the assessments contained in this Document. Where data supplied by the client or other external sources, including previous site investigation data, have been used, it has been assumed that the information is correct unless otherwise stated. No responsibility is accepted by Golder for incomplete or inaccurate data supplied by others. Golder may have retained subconsultants affiliated with Golder to provide Services for the benefit of Golder. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have any direct legal recourse to, and waives any claim, demand, or cause of action against, Golder’s affiliated companies, and their employees, officers and directors. This Document is provided for sole use by the Client and is confidential to it and its professional advisers. No responsibility whatsoever for the contents of this Document will be accepted to any person other than the Client. Any use which a third party makes of this Document, or any reliance on or decisions to be made based on it, is the responsibility of such third parties. Golder accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this Document.

GOLDER ASSOCIATES PTY LTD GAP Form No. LEG 04 RL 1

Golder Associates Pty Ltd Level 3, 1 Havelock Street West Perth, Western Australia 6005 Australia T: +61 8 9213 7600

REPORT - International Cyanide Management Code · International freight forwarding and multimodal...

Documents

Transcript of REPORT - International Cyanide Management Code · International freight forwarding and multimodal...