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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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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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1Responsible Manager Environmental
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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)
Significance(a+b+c) x d
Correctiveaction required
AAplcLevel 1, 2 or 3
(e)
YES NO
DESCRIPTION OF IMPACT ON WATER:
...
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 FAUNA & FLORA:
...
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
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DESCRIPTION OF IMPACT ON COMMUNITY:
...
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 OTHER PARAMETER SUCH AS:
...
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
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
Level 2 incidents No of incidents during the reporting period that resulted in:
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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Level 3 incidents No of incidents during the reporting period that resulted in:
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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