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EMP – Draft 001 - 1 -

Republic of South Africa ASP

Environmental Management Plan

Safeguarding of Transport & Disposal of

Stocks of Obsolete Pesticides

November 2010

Prepared by Veolia ES (UK) Ltd

EMP – Draft001 - 2 -

Republic of South Africa ASP


Safeguarding of Transport & Disposal of

Stocks of Obsolete Pesticides

List of Contents:

i. abbreviations & acronyms

1. Background ....................................................................................................................................... - 7 -

1.1 Project Aims: ............................................................................................................................ - 7 -

Part A. ...................................................................................................................................................... - 7 -

Part B ....................................................................................................................................................... - 7 -

1.2 Regulatory Framework ............................................................................................................ - 9 -

1.3 Review of Legislative Requirements ...................................................................................... - 10 -

1.3.1 National Regulations ......................................................................................................... - 10 -

1.3.2 International Regulations including EC requirements ...................................................... - 11 -

1.4 Objectives of the EMP ........................................................................................................... - 14 -

1.5 Storage site description of Holfontein Hazardous Waste Landfill Site & Gauteng Municipal

Store - 14 -

1.5.1 Holfontein HWLS ............................................................................................................... - 14 -

1.5.2 Gauteng Municipal Store .................................................................................................. - 15 -

1.6 Inventory profile Obsoletes pesticides and associated wastes ............................................. - 15 -

1.6.1 General overview of the inventory ................................................................................... - 16 -

1.6.2 Methodology of data recording. ............................................................................................ - 16 -


2 Risk Assessment for Holfontein & Gauteng Sites .......................................................................... - 17 -

3 Command Structure ............................................................................................................................ 27

3.1 Organizational structure ............................................................................................................ 27

3.1.1 Management Structure ......................................................................................................... 27

3.2 Roles and Responsibility ............................................................................................................ 27

3.3 Personnel Expertise and capacity reinforcement...................................................................... 28

4 Communication ................................................................................................................................... 31

4.1 Off –site communication ........................................................................................................... 31

4.1.1 List of Contacts ...................................................................................................................... 31

4.1.2 Emergency Communication Plan ............................................................................................... 32

4.2 On -site communication ............................................................................................................ 33

4.2.1 Briefings ..................................................................................................................................... 33

4.2.2 Reports ....................................................................................................................................... 33

4.2.3 Hazards Communication ............................................................................................................ 33

5. Occupational Health ...................................................................................................................... 34

5.1 Medical Examinations ................................................................................................................ 34

5.2 Worker Insurance ...................................................................................................................... 34

5.3 Relevant equipment .................................................................................................................. 34

5.4 Decontamination Facilities ........................................................................................................ 35

6. Operational Risk Assessment .............................................................................................................. 35

6.1 TBRA Holfontein/Gauteng ......................................................................................................... 36

7. Standard Operating Procedures/Method Statement ......................................................................... 37

7.2 Loading and off-loading of vehicles ........................................................................................... 40

7.3 Transport Rules .......................................................................................................................... 40

7.4 Transport Route Assessment and Selection .............................................................................. 41


8. Workplan/Timescale ........................................................................................................................... 43

9. M&E .................................................................................................................................................... 45

10. Annexes

Annex 1 Legislation Checklist

Annex 2 Inventory

Annex 3 Curriculum Vitae

Annex 4 Project Report Format

Annex 5 Typical Decontamination Unit Layout

Annex 6 Task Based Risk Assessment

Annex 7 Method Statements / SOP

Annex 8 Transport Route Maps


i. Abbreviations/ACRONYM/

ADR International regulations for the carriage of hazardous substances by road

ASP Africa Stockpiles Programme

CESA Country Environmental and Social Assessment

CLI CropLife International

CV Calorific Value

DEA Department of Environmental Affairs (Republic of South Africa)

DLCO Desert Locust Control Organisation

DoARD Department of Agriculture and Rural Development

DRR Duly Reasoned Request

EMP Environmental Management Plan

EMTK FAO‟s Environmental Management Tool Kit

EU European Union

FAO Food and Agriculture Organization of the United Nations

FIBC Flexible Intermediate Bulk Container – “Big-Bag”

GPS Global Positioning System

IMDG International Maritime Dangerous Goods Code

IMO International Maritime Organization

km kilometer

MSDS Material Safety Data Sheet

NGO Non Governmental Organization

PPE Personal Protective Equipment

RTA Road Traffic Accident

SANS South African National Standard

SOP Standard Operational Procedure


SCU Shipping Container Unit

TBRA Task Based Risk Assessment

TFS Transfrontier Shipment

UN United Nations

te tonnes (Metric)

WHO World Health Organization

WSR Waste Shipment Regulations

XRF X-ray Fluorescence


1. Background During a pilot collection initiative implemented in the Republic of South Africa under the African Stockpiles Programme a total quantity of 86 tonnes of obsolete agrochemical stocks has been identified, collected and is currently stored at two sites in Gauteng Province waiting final repackaging for transport and disposal to a suitably licensed High Temperature Incineration Plant in Europe. The majority of these wastes (the Limpopo and Wagtail stocks) are currently stored in 40‟ maritime shipping containers at the Holfontein Hazardous Waste Landfill site with a much smaller quantity stored at the Gauteng Municipal Store (the Gauteng stocks). The Limpopo & Wagtail stocks were accumulated during a series of regional obsolete pesticide collection programmes carried out during previous projects by a number of stakeholders.

1.1 Project Aims:

Following conclusion of an Agreement between Department of Environmental Affairs (DEA) and CropLife International (CLI) a Contract has now been placed by CLI with Veolia Environmental Services (UK) Ltd for the following activities and outputs:

Part A.

1. Drawing up of a Workplan to show the sequence and timing of the services and deliverables listed below, with special attention to the timing of inputs and activities to be undertaken by DEA.

2. Drawing up of an Environmental Management Plan (the current document) and its submission to CropLife and to DEA.

Part B, following agreement between the Parties on the Workplan and Environmental

Management Plan

3. Verification of the nature of the wastes, to include sampling and analysis of the unknown obsolete pesticides as necessary, to implement the services and deliverables below in full compliance with national and international laws and conventions

4. Arrangement of all necessary permits, approvals, financial guarantees and documentation specified in the Workplan


5. Provision to the Sites of necessary operational and safety equipment as reflected in the Workplan and EMP.

6. Provision to the Sites of necessary and suitable packaging materials to include shipping cargo units (SCUs) and UN-accredited steel drums or other appropriate packaging materials that are both suitable and fully compliant with the International Maritime Dangerous Goods Code (IMDG Code) requirements for these products

7. Provision to the Sites of necessary and suitable labelling materials

8. Repacking as necessary of the obsolete pesticide stocks into appropriate packing materials.

9. Draining of any emptied original or temporary containers and inclusion of the recovered product with the obsolete pesticides to be repacked.

10. Packing into drums or otherwise of any empty and drained packaging so that they are both suitable and fully compliant with IMDG Code requirements

11. Loading of all packed wastes as described above into SCUs in compliance with IMDG requirements and with best professional practice.

12. Overland transportation of the filled SCUs to the port of export, as described in the EMP, and temporary storage of the SCUs at the port or export if required.

13. Onward shipment of the filled SCUs to the final disposal facility as defined in the Workplan and notified to the recipient country.

14. Complete destruction or treatment by high temperature incineration of the wastes comprising:

a. Up to 85 tonnes of the defined obsolete pesticide stocks b. The associated packaging materials and cleaning wastes estimated at 10 tonnes.

15. Issuing a certificate of safe and environmental sound destruction within 30 days of final destruction, in the form of a duly completed Transfrontier Movement Tracking Form.


16. Establishing and maintaining accurate records of all activities and outcomes on a daily basis. Any and all variations from the EMP and any accident or mishap occurring during the works will be subject to special reporting procedures to be agreed with DEA during development of the Workplan and the EMP.

17. A full documentary and photographic report of the Works on completion of the project

together with a file in electronic format of all photographs, records and other relevant documents produced and acquired by the Contractor during the Project.

1.2 Regulatory Framework

In order to comply with the requirements of the World Bank Grant Agreement with the Government of South Africa, this Environmental Management Plan has been prepared prior to commencing operational activities.

The project will also be implemented in compliance with the national regulations specifically:

Occupational Health & Safety Act (85 of 1993) Hazardous Substances Act (15 of 1973 amended) National Road Traffic Act (93 of 1996) SANS Standards e.g. 1023/1/2: 1518-1 and 10228 National Environmental Management Act 107 of 1998 National Environmental Management: Waste Act, 2008 (Act 59 of 2008) National Water Act 36 of 1998

SANS Codes

SANS 10232-4:2007 (Edition 3) SANS 1518:2008 (Edition 3) “Transport of dangerous goods – Design, construction, testing, approval and maintenance of road vehicles and portable tanks”, SANS 10228:2006 (Edition 4) “The identification and classification of dangerous substances and goods for transport”, SANS 10229-1:2005 (Edition 1) and -2:2007 (Edition 1) “Transport of dangerous goods – Packaging and large packaging for road and rail transport”, SANS 10231:2006 (Edition 3) “Transport of dangerous goods – Operational requirements for road vehicles”, SANS 10232–1:2007 (Edition 3) “Transport of dangerous goods – Emergency information systems”, Part 1: “Emergency information system for road transportation”, SANS 10232–3:2007 (Edition 3) “Transport of dangerous goods – Emergency information systems”, Part 3: “Emergency action codes” and SANS 10233:2008 (Edition 3) “Transport of dangerous goods – Intermediate bulk containers for dangerous substances”. SANS 10232–1:2007 (Edition 3) “Transport of dangerous goods – Emergency information systems”, Part 1: “Emergency information system for road transportation”, SANS 10229-1:2005 (Edition 1) and -2:2007 (Edition 1) “Transport of dangerous goods – Packaging and large packaging for road and rail transport”, and SANS 10233:2008 (Edition 3) “Transport of dangerous goods – Intermediate bulk containers for dangerous substances”.

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SANS 10231:2006 (Edition 3) “Transport of dangerous goods – Operational requirements for road vehicles”,

The project is also bound to comply with a number of International and European

Conventions and Regulations associated with the international movement of hazardous

waste material, namely:

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (Basel Convention)

International Maritime Dangerous Goods Code of the International Maritime Organisation

Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste (Waste Shipments Regulation - WSR )

Hazardous Waste Directive of the European Community (Annexes I, II and III to Council Directive 91/689/EEC)

Waste Incineration Directive 2000/76/EC The Environmental Protection (Duty of Care) Regulations 1991 The Hazardous Waste (England and Wales) Regulations 2005 Environmental Protection – The Transfrontier Shipment of Waste Regulations 2007 SI 2007/1711 (TFS Regulations) Annexes I, II and III to Council Directive 91/689/EEC Environmental Protection Act 1990 (EPA 1990) Pollution Prevention & Control (England & Wales) Regulations 2000 European Waste Catalogue (Commission Decision 2000/532/EC) Following are also some relevant Guidelines and Standards namely: SANS Standards included in legal register The EMP takes into account relevant international guidelines in obsolete pesticide stock safeguarding operations and specifically follows the format provided in the Food & Agriculture Organisation of the United Nations (FAO) Environmental Tool Kit (EMTK) series for obsolete pesticide stocks management.

1.3 Review of Legislative Requirements

As the first stage of the Environmental Management Plan process it is necessary to undertake a detailed review of the applicable legislative requirements at a National and International level. As a result of this review a detailed list of key compliance issues has been produced in the form of a checklist. A summary of the main areas of legislative compliance is provided below and a copy of the checklist is attached as Annex 1.

1.3.1 National Regulations

RSA legislative requirements are included in the Legislation Compliance Checklist

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1.3.2 International Regulations including EC requirements

Transfrontier Waste Shipment

In the late 1980s, a tightening of environmental regulations in industrialised countries led to a dramatic rise in the cost of hazardous waste disposal. Searching for cheaper ways to get rid of the wastes, “toxic traders” began shipping hazardous waste to developing countries and to Eastern Europe. When this activity was revealed, international outrage led to the drafting and adoption of The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.

Imports into the European Community are dealt with under REGULATION (EC) No 1013/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 June 2006 on shipments of waste. This is more commonly known as The Waste Shipments Regulation.

In the United Kingdom, Parliament has enacted The Transfrontier Shipment of Waste Regulations 2007 SI 2007/1711 to implement the requirements of EC1013/2006 into Law.

Before any shipments of hazardous waste can be initiated, the competent authority of destination (UK) must approve the shipments by way of consent to a transfrontier or transboundary shipment document (TFS). For imports into a European Member State, a Duly Reasoned Request (DRR) must be submitted by the country of dispatch (RSA) to the country of destination.

The application process for TFS documents is common to all European Member States. However, the U.K. requires that a Duly Reasoned Request be submitted and acceded to prior to submission of the TFS Notification package for assessment.

Veolia will on behalf of the Notifier (DEA) put together the TFS Notification package which shall consist of the following:

Notification Form, completed as per, and signed and dated in Block 17 by the Notifier and Producer (if different);

Movement Form;

Associated and referenced annexes as applicable;

Non-commercial agreement signed and dated by the Notifier (DEA) and the Consignee (Veolia ES UK);

Financial Guarantee

The Notifier (DEA) shall present the whole package to the competent authority of dispatch (also DEA) who shall submit the documents, to the competent authority of destination (Environment Agency of England & Wales). Copy packages shall be sent to any competent authorities of transit. The competent authority of destination will acknowledge receipt of the Notification by stamping and signing Block 19 of the Notification Form. This is done within three working days of receipt of a notification that has been properly carried out. If the notification has not been properly carried out, the competent authority of destination shall request information and/or documentation. The competent authority of destination shall send the

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acknowledgement to the Notifier and copies to the other competent authorities concerned. The competent authorities of destination, dispatch and transit shall have 30 days following the date of transmission of the acknowledgement by the competent authority of destination in which to take one of the following duly reasoned decisions in writing as regards the notified shipment(s): a) consent without conditions b) consent with conditions in accordance with Article 10 of the WSR or c) objections in accordance with Articles 11 and 12 of the WSR

Tacit consent by the competent authority of transit may be assumed if no objection is lodged

within the 30-day time limit.

The competent authorities of destination dispatch and where appropriate, transit, shall signify their written consent by stamping, signing and dating the notification document in Block 20. Written consent to a planned shipment shall expire one calendar year after it is issued or on such later date as is indicated in the notification document. Transboundary Movement Forms provide a cradle to grave trail for the international shipments of hazardous waste. All international movements of hazardous waste have to be pre-notified to the relevant authorities at least three clear working days before the movement begins. The pre-notification package is faxed by Veolia on behalf of the Notifier and consists of:

The Movement Form

The Approved Notification Form

Associated Annexes

The movement package accompanies the waste from the holder to the disposal or recovery site. When the waste arrives at the disposal or recovery site Block 18 is completed to signify acceptance. When the disposal or recovery operation is completed block 19 is completed to signify completion of the disposal or recovery of that consignment. The completed movement forms are sent to the Notifier with a certificate of destruction. Packaging and Labelling of Waste Under the requirements of the International Maritime Dangerous Goods (IMDG) Code all packaging materials must bear the correct UN Code and all test certificates shall be available to ensure fitness for the proposed purpose. All packages must be fully compliant with all aspects of the IMDG Code. No material will be transported if these requirements cannot be verified or if the packaging is not considered fit for safe transport to the final disposal site. The correct UN Number will be assigned to each waste material and package labels bearing this together with the Proper Shipping Name, Hazard Warning diamonds, Marine Pollutant Mark and an Emergency Contact Number will be fixed to each package in compliance with the IMDG Code. Liquid waste should be re-packaged into epoxy phenolic lacquer lined steel or polypropylene

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United Nations (UN) approved drums of category 1A or 1H1/Y or X. Solid waste, including small containers of liquids should be re-packaged into new epoxy phenolic lacquer lined steel or polypropylene United Nations (UN) approved drums of category 1A or 1H2/Y or X. Powders may also be re-packaged into U.N. approved 1 cubic meter Flexible Intermediate Bulk Containers (FIBC) or „Big-Bags‟ of category 13H3 or 13H4. Contaminated Packaging (including crushed steel drums) should be transferred into U.N. approved 1 cubic meter Flexible Intermediate Bulk Containers (FIBC) or „Big-Bags‟ of category 13H3 or 13H4for ease of handling. Bags should not be overfilled (by weight or volume) and no free liquid or malodorous material should be present in any material loaded in this type of container.

Dangerous Goods Notes

Dangerous Goods Notes (DGN) are used for the purpose of shipping hazardous waste by sea as detailed in the International Maritime Dangerous Goods Code (IMDG). The dangerous goods note (DGN) must:

Identify the hazardous waste to which it relates, and specify:

Waste quantity and volume of waste

Type of container

Proper Shipping Name

UN Number

IMO Hazard Class

Packing Group The DGN is prepared by the Veolia Field Services Site Supervisor and accompanies the waste from the holder to the disposal or recovery site. Disposal Operations The High Temperature Incineration disposal facility at Elsmere Port is licensed under the Pollution Prevention & Control Regulations for England & Wales 2000. Accordingly the site operates under permit number BS5193IE for the incineration of hazardous waste. The plant also operates under a stringent management system accredited to ISO 9001, 14001 and 18001 standards. The operating conditions of the plant are set out in considerable detail within the operating permit however in summary it a requirement that all waste accepted on to the site is analysed and tested to ensure that it is suitable for incineration. The incineration process is controlled by an integrated computer system that monitors every aspect of the operation, providing continuous readouts of operational parameters and emissions. Specific measurement of stack and effluent emissions is also carried out along with regular monitoring by the Environment Agency to ensure compliance with the terms of the permit.

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1.4 Objectives of the EMP

Provide on-site data (location, access roads, immediate environment, addresses and contacts of services and those responsible for management, site security, etc)

Assess the conditions of the stocks and sample and analyse “unknown” wastes to enable compliance with transport regulations and to ensure disposal site acceptance.

Identify hazards and risks posed by the planned operations on health and the environment in both sites and the transport route;

Identify tasks to be carried out on sites and enact measures to reduce risks accordingly;

Provide a monitoring plan of work and management plan of personnel involved and a plan of information and communication (in the direction of site workers and other stakeholders outside the site).

1.5 Storage site description of Holfontein Hazardous Waste Landfill Site & Gauteng Municipal Store

1.5.1 Holfontein HWLS

The Holfontein HWLS is a large H:H Landfill facility operated by Enviroserv Waste Management (Pty) Ltd situated approximately 55Km east of Johannesburg, Gauteng. The site is an active waste management facility and operates according to National Regulations. The obsolete stocks are stored in 12 x 40‟ modified maritime shipping containers positioned on the contained/lined landfill area away from active “tipping” operations.

Access to the site entrance is via a public road approximately 5Km from the N12. The site has a high security perimeter fence and the only access on to the site is via a manned security check point adjacent to the weigh bridge and site offices at the Western side of the site.

Due to the nature of the operations undertaken at the Holfontein HWLS all site staff are trained in relation to the risks associated with landfill activities and working with hazardous waste materials. All visitors are subject to safety induction and are escorted whilst on site.

1.5.1.1 General description

Working Area:

The working area will constitute the footprint of the 12 containers together with a level, gravel area to be constructed in front of the containers to provide a dry, firm working surface for handling and repackaging of the wastes. This area is within the contained/lined area of the landfill site; i.e. the area of the landfill where waste can be deposited. The working area will be segregated using temporary fencing and warning signs. Access to the working area

EMP – Draft001 - 15 -

will be controlled by Enviroserv who will have a coordinating supervisor assigned to the operation on a permanent basis.

Access to the working area is via the temporary “haul road” network across the landfill from the weighbridge and is only suitable for large commercial or four wheel drive vehicles. Access can also be limited or prevented during periods of prolonged or heavy rain.

i.

1.5.1.2 Store Plan – Holfontein

All waste material is currently stored within the 12 maritime shipping containers. It is envisaged that waste will be removed from the containers for inspection, sampling and repackaging and returned to the containers on a daily basis. At the same time liquid and solid waste will be segregated such that at the end of the repackaging operations all liquids and solids will be stored separately within the containers.

The containers will remain on the contained/lined area of the landfill site prior to loading and transport out of RSA.

1.5.2 Gauteng Municipal Store

The Gauteng store is within the Department of Agriculture and Rural Development storage and distribution centre at Simmonds Southway, Selby, Johannesburg. It is situated in an industrial area approximately 0.5km southwest of the Crown Interchange. The site is used for the storage and distribution of tools, equipment and seed for a regional program supporting home vegetable cultivation.

1.5.2.1 General description of Working Area

The obsolete stocks are stored in a modified 20‟ maritime shipping container at the rear of the site and is situated within a large level, gravel surfaced yard area also used to store farm machinery and fencing materials. The container is locked at all times. Access to the site is via the main site entrance and is suitable for large commercial vehicles to enter and turn. At busy times access can be limited by the quantity of equipment in storage.

1.5.2.2 Store Plan for Gauteng Store

All the obsolete stocks are within the modified container and the working area during repackaging will include the container and an area immediately adjacent to the doorway. Repackaged waste will be returned to the shipping container for interim storage prior to export.

1.6 Inventory profile Obsoletes pesticides and associated wastes

All data presented has been provided by CropLife International (CLI).

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1.6.1 General overview of the inventory

The database includes 618 items for Limpopo, 706 items for Wagtail and 59 items for Gauteng stores, 1 record per container (package).The database includes the following items only:

Serial No (CLI, DEA & Original)

Package Type (e.g. drum, big bag)

Physical (Solid/liquid)

Trade Name

Active Ingredient

Formulation type

Net weight (kg)

This data base is held by the CLI and Veolia as an Excel inventory record.

1.6.2 Methodology of data recording.

The inventory data was collected during the repackaging operations in Limpopo and the Wagtail project, data for the Gauteng store was collected by CLI. The data has been reviewed and consolidated by CLI and provided to Veolia as the basis of the current project. A copy of the inventory is attached as Annex 2 to this EMP. Within the inventory there is a substantial quantity of unknown material that will require laboratory analysis in order to determine transport classification and ensure disposal site acceptance. It is planned to test samples as follows: Calorific Value (CV), Flashpoint to determine flammability, X-ray Fluorescence (XRF) (full scan of metals etc) & pH

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2 Risk Assessment for Holfontein & Gauteng Sites This assessment has been conducted based on the principle and tools presented in FAO EMTK Volume 1. It has been undertaken to identify the principal risks associated with the operations to be undertaken in order to identify key control measures to be implemented in order to effectively manage the risks identified. In addition to this project level risk assessment, task based risk assessments have also been undertaken to control repacking, loading and transport activities at site level. These Task Based Risk Assessments are presented later in this Plan. The project activities subject to this assessment are as follows:

Existing Storage Arrangements Site Access Repacking Operations Loading Operations Transport of Repackaged Materials Pre-shipment storage at Port The risk assessment is presented in Table 1 below:

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Table 1 Project Level Risk Assessment

Holfontein Site

A – Existing Storage Arrangements

Aspect Potential Risks Mitigation

Measures Responsibility Comments

H&S

Exposure risk to

site

occupier/store

manager.

Waste currently in

locked containers,

remote from

occupied offices.

Access to

containers is

controlled by site

management.

Enviroserv Site

Management.

Containers are

fitted with roof

mounted draft

induced ventilation

to prevent build up

of vapour within

the containers.

Environment

Leaks/spills

from obsolete

stocks in poor

packaging.

Waste in

containers

situated on the

lined area of the

landfill site.

Containers are

inspected

regularly and any

spills cleaned up.

Enviroserv Site

Management.

The floors of the

maritime shipping

containers may be

considered as

contaminated and

will need suitable

cleaning prior to

removal from site.

Third Parties

Exposure of site

visitors to

hazardous

vapours/dusts.

Access to site

restricted.

Enviroserv Site

Management

There is no access

to the Holfontein

site to

unauthorised

persons.

B – Site Access



H&S

Waste is stored

on an active

landfill site,

large vehicles

Site Rules –

Personal

Protective

Equipment (PPE)

Enviroserv Site

Management &

Veolia

Enviroserv will

regulate access to

the site in line with

site rules. Veolia

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moving around

on dirt roads.

Risk of vehicle

collisions,

pedestrian

accidents and

hazardous

dust/vapours.

issued to protect

against dust and

vapour, no

pedestrian access

to the working

area only in

vehicles.

Supervisor. Supervisor to

coordinate with

Enviroserv.

Environment

Dust from

vehicles

travelling across

the site.

Site Rules –

speed limits,

damping

measures etc.

Enviroserv Site

Management.

Third Parties Unauthorised

access.

Site Security

measures.

Enviroserv Site

Management.

Site has high

security measures

on 24/7 basis.

C - Repacking Operations



H&S

Exposure risks

to staff carrying

out repacking.

Physical injury

risk to staff

handling

packages,

equipment etc.

Safe systems of

work to be

employed plus

supervision of

trained staff. Use

of PPE, good

manual handing

technique,

handling aids

such as trolleys

etc. Provision of

emergency

equipment e.g.

shower, eye wash

etc

Veolia Site

Supervisor.

For full details see

Working

Methods/Operating

Procedures in

following sections.

Environment

Spills of material

to ground during

repackaging.

Release of

dust/vapours.

Environmental

protection

measures

including use of

bunded area for

repacking, i.e.

Veolia Site

Supervisor.


Working

Methods/Operating

Procedures in

following sections.

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impermeable

polythene

membrane.

System of work to

avoid dust/vapour

release. Spill

response

procedures and

equipment in

place.

Third Parties

Other site staff

being exposure

to hazardous

dust/vapours.

Controlled access

to working area,

use of fencing,

warning signs,

good supervision.

Enviroserv Site

Management

and Veolia

Supervisor.

It is planned to

position containers

in an area away

from other

activities on site.

D - Loading Operations



H&S

Risk of vehicle

collisions,

pedestrian

collisions,

dropped loads.

Also manual

handling risks.

Safe systems of

work to be

employed plus

supervision of

trained staff.

Controlled vehicle

movements, use

of banksman etc.

Good manual

handing

technique,

handling aids

such as forklift,

trolleys etc

Veolia Site

Supervisor


Working

Methods/Operating

Procedures in

following sections.

Environment Spillages during

loading.

All waste

repacked into

approved

packaging. Level

Veolia

Supervisor


Working

Methods/Operating

Procedures in

following sections.

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load area to be

constructed, good

supervision of

trained staff. Spill

response

procedures and

equipment in

place.

Third Parties

Risk of

exposure to

dust/fumes to

vehicle drivers.

Drivers to receive

training/instruction

on risks. Driver to

remain in cab (or

in welfare unit)

during loading.

Veolia

Supervisor


Working

Methods/Operating

Procedures in

following sections.

Gauteng Site

A – Existing Storage Arrangements



H&S

Exposure risk to

site

occupier/store

manager.

Waste currently in

a locked

container, remote

from occupied

offices. Access to

containers is

controlled by site

management.

DoARD Site

Management.

Container is fitted

with ventilation to

prevent build up of

vapour within the

containers.

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Environment

Leaks/spills

from obsolete

stocks in poor

packaging.

Waste in sound

packages situated

within the

container.

Container is

inspected

regularly and any

spills cleaned up.

DoARD Site

Management.

The floors of the

maritime shipping

containers may be

considered as

contaminated.

Third Parties

Exposure of site

visitors to

hazardous

vapours/dusts.

Access to site

restricted.

DoARD Site

Management

There is no access

to the Gauteng site

to unauthorised

persons.

B – Site Access



H&S

Waste is stored

at an

operational

distribution

depot, large

vehicles moving

around. Risk of

vehicle

collisions,

pedestrian

accidents.

Site Rules –

control of vehicle

movements. High

viz waist coats.

DoARD Site

Management &

Veolia

Supervisor.

DoARD will

regulate access to

the site in line with

site rules. Veolia

Supervisor to

coordinate with

DoARD.

Environment None

Third Parties Unauthorised

access.

Site Security

measures.

DoARD Site

Management.

Site has high

security measures

on 24/7 basis.

C – Repacking Operations



H&S Exposure risks

to staff carrying

out repacking.

Safe systems of

work to be

employed plus

Veolia Site

Supervisor.


Working

Methods/Operating

EMP – Draft001 - 23 -

Physical injury

risk to staff

handling

packages,

equipment etc.

supervision of

trained staff. Use

of PPE, good

manual handing

technique,

handling aids

such as trolleys

etc. Provision of

emergency

equipment e.g.

shower, eye wash

etc.

Procedures in

following sections.

Environment

Spills of material

to ground during

repackaging.

Release of

dust/vapours.

Environmental

protection

measures

including use of

bunded area for

repacking.

System of work to

avoid dust/vapour

release. Spill

response

procedures and

equipment in

place.

Veolia Site

Supervisor.


Working

Methods/Operating

Procedures in

following sections.

Third Parties

Other site staff

being exposure

to hazardous

dust/vapours.

Controlled access

to working area,

use of fencing,

warning signs,

good supervision.

DoARD Site

Management

and Veolia

Supervisor.

The container is

positioned away

from other

activities on site.

D – Loading Operations



H&S

Risk of vehicle

collisions,

pedestrian

collisions,

dropped loads.

Also manual

Safe systems of

work to be

employed plus

supervision of

trained staff.

Veolia Site

Supervisor.


Working

Methods/Operating

Procedures in

following sections.

EMP – Draft001 - 24 -

handling risks. Controlled vehicle

movements, use

of banksman etc.

Good manual

handing

technique,

handling aids

such as forklift,

trolleys etc.

Environment Spillages during

loading.

All waste

repacked into

approved

packaging. Level

load area to be

constructed, good

supervision of

trained staff. Spill

response

procedures and

equipment in

place.

Veolia

Supervisor


Working

Methods/Operating

Procedures in

following sections.

Third Parties

Risk of

exposure to

dust/fumes to

vehicle drivers.

Drivers to receive

training/instruction

on risks. Driver to

remain in cab (or

in welfare unit)

during loading.

Veolia

Supervisor


Working

Methods/Operating

Procedures in

following sections.

Both Sites

E - Transport of Waste



H&S Road Traffic

Accident.

Transport plan to

cover routing,

trained drivers,

licensed and well

Veolia

Supervisor &

Haulier

EMP – Draft001 - 25 -

maintained

vehicles. Driver

briefing etc.

Environment

Spillage during

transport or as

result of RTA.

All material

packed in

approved

packages.

Shipping

containers loaded

and secured to

correct standard.

Spill response

plan in place for

all journeys.

Veolia

Supervisor &

Haulier

For Full details

see Transport

Plan in following

sections.

Third Parties

Exposure

resulting from

spillage.

Transport plan to

identify

stakeholders on

route, spill

response plan in

place for all

journeys.

Veolia

Supervisor &

Haulier

For Full details

see Transport

Plan in following

sections.

F – Storage at Port



H&S Risk of dropped

load at Port.

Safe operating

procedures at

Port.

Port authority.

Port has

dedicated,

managed area

for storage of

dangerous

goods in line

with

International

Maritime

Organisation

guidelines.

Environment Spillage at Port

All material

packed in

approved

packages.

Port authority Port has spill

response plan

for dangerous

EMP – Draft001 - 26 -

Shipping

containers loaded

and secured to

correct standard.

goods.

Third Parties

Exposure

resulting from

spillage.

Safe operating

procedures at

Port.

Port authority

Following loading of the containers of waste to the vessel at Durban the responsibility for the

subsequent management of the waste including sea shipment, delivery and final disposal of the

waste rests with Veolia ES UK Limited who have been Contracted by CropLife International.

Disposal of the waste will be carried out at Veolia‟s High Temperature Incineration Plant at

Elsmere Port, Cheshire, UK.

EMP – Draft001 27

3 Command Structure

3.1 Organizational structure

The following section sets out the organizational structure that will be in place for the

management of this component of the pesticide disposal project.

3.1.1 Management Structure

The project implementation is managed by the Department of Environmental Affairs through the Directorate of Waste Stream Management.

General supervision for the operational activities will be provided by Veolia who will under their Site Supervisor ensure this aspect is completed in compliance with this Environmental Management Plan (EMP). The Veolia Site Supervisor will also be responsible for the implementation of all site activities at Holfontein and Gauteng stores.

The Project Field Team will be formed by Veolia from existing employees of Veolia Environmental Services in the UK and South Africa. The team is composed of 1 Hazmat Technicians and three operators in addition to the Site Supervisor and will be responsible for repackaging, handling, and pumping, labelling, and loading.

Monitoring and evaluation will be undertaken by DEA along with an independent NGO for the project Endangered Wildlife Trust.

3.2 Roles and Responsibility

DEA will have the overall responsibility for the project and will facilitate the work of Veolia especially in areas of planning, liaison with Enviroserv, notification and communications to other government agencies within South Africa and overseas as well as supporting timely signing of official documents, communications and permissions relating to the services to be carried out by Veolia and will act as Notifier for the purpose of Basel Convention procedures.

DEA will monitor Veolia‟s activities and will have sanction over the same to ensure compliance with DEA standards and with the operational terms and conditions of the Contract. Veolia will grant to DEA at any time access to all documents, materials, records and information necessary for DEA to perform such monitoring, the appointed NGO may also be involved in this monitoring as appropriate.

DEA will be responsible for all official communication, especially those with the general public or with the media (e.g. response to complaints, press/media quires, etc.). As such, all complaints, press/media queries, etc. will be referred to the appointed DEA representative.

EMP – Draft001 28

As this is a World Bank-associated project, the final Work plan and EMP will require „no objection‟ endorsement from the World Bank. DEA will be responsible for obtaining this endorsement.

Veolia will take full liability for the waste from the moment of repacking/containerisation at the Holfontein and Gauteng sites up to final disposal, subject to legal obligations incumbent on the Government of South Africa as the legal owner of the wastes.

3.3 Personnel Expertise and capacity reinforcement

Veolia Site Supervisor

In-country operations will be carried out by the Veolia Site Supervisor supported by Veolia‟s local management. Our Project Manager is a qualified Chemist with wide experience of environmental remediation projects in the UK and overseas. The Project Manager will be responsible for day to day liaison with DEA. He will also act as the safety co-ordinator for site work. He will be based in South Africa throughout the verification and export phases of the project. In addition he will be involved in project planning stages.

Members of the Veolia Environmental Services (VES) Field Team are externally trained in the

following:

IMDG - The International Maritime Dangerous Goods Code (which governs the movement of shipments of hazardous cargoes by sea)

ADR – agreement for the carriage of dangerous goods by road

The use of Breathing Apparatus

Fire Fighting

First Aid

Forklift Truck Driving

CPL – classification, packaging and labelling regulations

Scaffold Tower erection

Slinging & lifting

Tank entry & cleaning

Manual handling

Safety Management

Risk Assessment

Project Management

CVs for key project staff are attached as Annex 3 to this EMP.

EMP – Draft001 29

Prior to commencing work on site all staff will receive a short training program from the Veolia Site Supervisor as follows:

Health & Safety awareness

Procedures and control measures for repackaging, handling and transport activities involving hazardous waste.

EMP – Draft001 30

Figure 1: Organogram of Management Structure for the Operation

Department of Environmental Affairs

Veolia Environmental Services (VES)

Site Supervisor

VES Hazmat

Technician

Enviroserv

Haulier in South

Africa

Site Operators

EMP – Draft001 31

4 Communication As stated above DEA will be the focal point for communication without outside organisations and the general public. Veolia will provide regular updates on project progress and activities in order to support DEA in this regard. At site level the Veolia Supervisor will be responsible for communication with Enviroserv and DoARD site management at the two sites.

4.1 Off –site communication

4.1.1 List of Contacts

In order to ensure clear lines of communication the following contacts have been identified and verified for use in case of an incident or emergency:

Emergency Contacts List

Project Contacts

Role Mobile Other Contact person

DEA Coordinator

082 772 9837

Dee Fischer

CropLife International

+27 83 305 2700

Les Hillowitz

Veolia Site Supervisor

+44 7812 963 620

Edward Hall

Veolia Hazmat Technician

072 156 2424

Ross Arde

Veolia Field Service Manager (UK)

+44 7767 230 075

+44 1495 768028

Nick Morgan

Veolia Regional Manager (Gauteng)

083 288 4479

Dirk de Wet

Value Logistics / Freightpak Manline

0860 2000 46 033 846 0000

Melanie

Enviroserv Ltd Contact

082 562 1230.

WAYNE HUMPHRIES REGIONAL HAZMAT OPERATIONS MANAGER

Port of Durban 031 361 8582 / 031 308 8260/1

Harbour Master

Port of Durban: Pollution Control Officer

083 283 3506

031 361 6475 /

Edward Mpungose

Port of Durban: 083 278 031 361 Vikesh Dayaram

EMP – Draft001 32

Marine Safety Inspector

3928 8457 /

Port of Durban Marine Safety Inspector

083 579 1283

031 361 8518 /

Pradhani Lazarus

Emergency Contacts

Role Mobile Other Contact person

Spill Response (Drizit)

084 338 4431

0800202202 Terence Fynn

Fire Department (Gauteng)

011 458 0911

Fire Department (Durban)

031 361 0000

Emergency Medical Service (Netcare)

082911

Police Department (Gauteng)

011 458 0911

10111 (National)

Police Department (Durban)

10111 10111 (National)

Toll Road Operator (Tolcon)

082 822 2938

0800 634 357

Gideon Cloete

4.1.2 Emergency Communication Plan

Prior to commencing site operations a copy of the Contacts list will be provided to the site management (at Holfontein and Gauteng) for use in an emergency together with the following information to be provided to the emergency services in case of an incident: Site Plan Details/number of staff on site Details of Chemical Hazards on site Types & Number of packages Type and location of emergency equipment A further copy will be held by the Veolia Site Supervisor in the site file. In the case of an emergency the Veolia Site Supervisor will coordinate the response at the working area and liaise with the site manager if the incident affects the wider site or off site. In the case of any incident having an impact outside the working area at Holfontein the Enviroserv Site manager will coordinate communication with the Emergency Services in conjunction with the Veolia Supervisor. The DEA Coordinator will be informed at the earliest opportunity and within 24hrs.

EMP – Draft001 33

4.2 On -site communication

4.2.1 Briefings

Workforce briefings are to be held: At the beginning of the working day in order to inform all staff of planned operations and control measures for the day ahead. At the end of the working day to update on activities undertaken, progress of operations, challenges and constraints encountered. When there is a significant change to planned operations or control measures in place, e.g. when changing from unloading to repackaging activities. All briefings will be conducted to include all staff involved in handling the pesticides prior commencing work and will include routine and emergency actions on site and during transportation. Prior to transportation of pesticide wastes all vehicle drivers will be briefed on hazards of obsolete pesticides and safety procedures to be taken during transport including the agreed route and specific control measure such as reduced speed limits.

4.2.2 Reports

In accordance with the established methodology of the FAO EMTK, a reporting system will be established. Veolia will produce, according to the format devoted a daily briefing, reports of daily and weekly progress of all operations. These reports will be distributed in hard format and email to DEA/CropLife at the beginning of each week. The format of the reports is shown in Annex 4 of the EMP.

4.2.3 Hazards Communication

Prior to commencing operations the Veolia Site Supervisor will provide a pre-start workforce briefing for all operational staff. As part of this induction training the Veolia Supervisor will provide information on the hazards identified at the working site with respect to the planned activities together with information on the risk assessment undertaken and the control measure to be implemented. Daily site briefings will then reinforce these aspects for the operations to be undertaken each day along with any variations to the planned method of work.

EMP – Draft001 34

5 Occupational Health

5.1 Medical Examinations

Prior to initiation of operations, all field staff, will be subject to a „fit for work‟ medical examination including the following:

Physical examination

Blood Pressure.

Eyesight

Audiometric assessment

Work history

Lung function

Urine sugar/protein screening

Medical Follow Up

Physical examination will be carried out at the beginning and the of the operational phases. There will be a further medical examination within 12 months following completion of the project.

5.2 Worker Insurance

All Veolia employed staff have workplace insurance under Veolia conditions of employment to cover workplace accident, injury or negative health impacts.

5.3 Relevant equipment

To reduce the risk of occupational exposure and environmental release the equipment to be used is the following:

UN approved drums/salvage drum

forklift or spill tray

vermiculite 1

electrical pump (explosion proof)

1 Vermiculite is a light weight inert absorbent material, which will absorb any liquid in case one of the inner

packaging will start leaking during the transport.

EMP – Draft001 35

appropriate chemical resistant coverall for liquid pesticides

cotton gloves and chemical gloves appropriate for the chemical hazards identified

half and full face mask with ABEKP32 filter

chemical resistant safety boot

Spill response equipment

5.4 Decontamination Facilities

A decontamination facility will be used on each repacking site to house all personnel belongings and equipment. This facility should be sited so that any personnel entering the storage area must enter the unit and any personnel leaving the work area must exit from the facility. What is essential is that there are two sides of the Decon facility: a clean side and a dirty side, separated by a decontamination facility (e.g. shower or serial washing). The decontamination unit will be set up within a tent or other temporary structure. A typical layout is enclosed as Annex 5 to the EMP.

6 Operational Risk Assessment In order to manage the operational risks associated with the activities to be undertaken Task Based Risk Assessment have been carried out for all principal tasks. The objectives of TBRA is to assess individual tasks to be undertaken in order to identify hazards, assess the level of risk and consider and specify control measures to be adopted in order to mitigate the risks identified. The TBRA is a methodology developed after over 15 years of project implementation management of waste in developing countries. It is based on standard methodologies of risk assessment. The TBRA aims:

To identify hazards;

To identify people who may be affected or impacted by these hazards;

To assess exposure;

To document all actions;

To analyze and revise the risk assessment in the course of operations. It is a format for recording data and information that can assist the operator in making objective decisions regarding the protection of workers and the environment. It also provides

2 Filter explanation: The letters ABKEP3 means withholding:

A organic gases with boiling point > 65°C

B Inorganic gasses (e.g. Cl2, HCN, H2S)

E Acidic inorganic gasses (e.g. SO2)

K Ammonia and amines

P particles < 0.3 μm

EMP – Draft001 36

a methodology for establishing an order of priority in safeguarding activities to reduce risks as and when they run.

6.1 TBRA Holfontein/Gauteng

A TBRA has been developed separately for the different activities:

Inspection of all packages

Repacking/Pumping/, Relabeling & Inspection of new drums

Transportation between Gotera/DLCO

Palletisation, Zoning and storage The TBRAs for the planned operations at Holfontein & Gauteng stores are attached as Annex 6 to the EMP.

EMP – Draft001 37

7 Standard Operating Procedures/Method Statement

The standard operating procedures (SOP) give detailed instructions on how work should be executed. As part of planned operations SOPs are developed in accordance with the duties of all workers on site to ensure proper execution of operations on time and safely.

To support the effective control of the site in conjunction with the SOPs the site is organised into a series of working Zones based on the level of risk and control required as follows:

At each of the sites where re-packaging is to be undertaken the first activity is to set up a safe place to work. To enable hand over of wastes to be undertaken in a smooth and professional manner, Veolia ES expects these guidelines, as modified during Project Planning, to be followed. Typically the sites will be divided into three areas dependent on level of contamination.

Zone A The Clean Area: outside work site, no risk of exposure

Zone B The General Site Area: within work site, low risk of exposure

Zone C The Working Area: direct contact with hazardous material, high risk of exposure

Entry from the clean area of site into the general site area will be via a designated changing area. This will be the only access point for personnel during site works. The boundary of the clean, general site and working areas will be clearly identified using sectional wire mesh fencing, warning placards and reflective hazard mesh and tape. Eating, drinking and smoking will only be allowed in the designated mess facility away from the work site.

Zone A The Clean Area

This will be away from the working areas and will comprise a mess unit for project staff (either by using an existing office or hiring a portable welfare unit), car parking area, delivery point and access to the general site. The removal of drummed and palletised wastes will be via this area.

Zone B The General Site Area

The general site area will be adjacent to the working area. This will include temporary holding areas for packaged wastes and equipment storage. It will be a buffer zone between the clean area and the working areas where re-packaging is undertaken. The boundary of the general site area will be made highly visible by use of warning placards, hazard mesh and wire fencing to ensure that there is no uncontrolled access to the areas of higher exposure risk.

The principal risks associated with the general work area are linked to the movement of packaged waste. The risk of exposure to harmful materials is slight, a greater risk is associated with manual handling of large packages. These will be minimised by the use of handling equipment such as drum trolleys and forklift truck where appropriate.

EMP – Draft001 38

Personal protective equipment (PPE) will be used by all PMT staff and locally hired labour and will include safety shoes, disposable overalls, rigger type gloves, safety glasses or goggles and hard hat where needed.

Zone C The Working Area

This is the storage area for redundant pesticide stocks in their original containers.

The essential principles of the use of clearly defined working areas include:

Providing an area in which it is safe to work

Prevention of cross contamination

Catering for eventualities such as spillages

Controlling access to essential personnel only

Provision of bunded areas to contain liquid wastes and cleaning solutions

Provision of changing areas for removal of personal protective equipment prior to leaving the working area

Following the demarcation of the general site area the working area will be clearly established as follows:

An Orange Hazard Warning Barrier will be erected around the perimeter of the working area to exclude non-working personnel.

A shoe and overall changing station will be set up at the entrance to the Working Area. All safety wear will be colour coded to eliminate the possibility of cross contamination into the general site area. White overalls will be used in the Working Area and blue overalls in the General Site Area.

If existing protection is not adequate the floor inside the Working Area will be covered with a protective membrane of heavy-duty polythene and plywood sheeting to prevent contamination of the floor area during works.

Upon completion of site work in the Working Area to the satisfaction of the Veolia ES Project Manager, and the Site Occupier, all protective membranes will be carefully removed for reuse at another site, or if contaminated or damaged, will be packaged for disposal.

Entry and Exit Procedures

Upon entering a Working Area all personnel will enter the Changing Station. This will be clearly set out with a single entry point into the Working Area. This will be segregated into Clean and Dirty Areas. The floor of the Changing Station will be protected with polythene sheeting. The Changing Station will be constructed to afford the only entry point to the working area.

Upon entering the Changing Station personnel will remove all overalls, gloves and boots within the clean zone of the Changing Station. Personal Protective Equipment (PPE) from the General Site area will be stored in the clean zone to be put back on when the team member leaves the Working Area.

EMP – Draft001 39

Personnel will then cross into the dirty area of the station. Here, suitable chemically resistant coveralls, respiratory protection, gloves and a second pair of boots (marked with identifying paint) will be worn. The only common PPE permitted for both areas will be eye protection in the form of safety glasses or goggles.

Upon completion of the working period as defined appropriate by the Project Manager, personnel will approach the entry to the Changing Station. If work wear is highly contaminated it ill be removed prior to entry into the Changing Station. All removed work wear will be drummed for disposal. Boots showing high levels of dust will be washed in a foot bath placed adjacent to the entry point.

Upon entering the Changing Station the reverse procedure to that detailed above will be observed. All discarded work wear will be drummed for disposal. The removal and inspection of PPE will form an integral part to the success of the Health and Safety strategy. It is planned that by controlling the work practices to a sufficient degree that levels of contamination to personnel will be minimal. The PPE used should, in this case, remain uncontaminated for the working day. If an activity/operation results in a member of the team becoming contaminated to unacceptable levels dictated by the PPE in use, a view will need to be taken as to whether the PPE should be discarded at the end of the working period. This will need to be an on the spot evaluation by the personnel concerned.

As a matter of policy all PPE will be discarded at the end of each working day unless in the General Working area. This working procedure will be reviewed and adapted by the Veolia ES Project Manager on site as deemed necessary.

7.1 Method Statements for Holfontein/Gauteng

Method Statements have been prepared for each of the key operational activities to be undertaken at the Holfontein and Gauteng sites as follows:

Entry & Exit to working area

Waste sampling

Decanting liquids

Redrumming liquids

Repacking solids/liquids

Overdrumming

Loading/unloading vehicles and containers

Cleaning spills

Rinsing and crushing drums Copies of these are attached as Annex 7 of the EMP.

EMP – Draft001 40

7.2 Loading and off-loading of vehicles

Veolia trucks fitted with cranes will be used to transfer drums between stores and the two sites. Specialist drum lifting equipment will be used in conjunction with the hydraulic arm to load and unload drums.

Photograph 1 - Crane Truck

7.3 Transport Rules

All movement of hazardous waste between the stores will be coordinated and supervised by Veolia. Specific transport rules will be applied including:

Safety Equipment in vehicles

Driver Training

Transport documentation including information on hazards and emergency actions

Vehicle Inspections

Driver Briefing

Incident response service

Planned route based on risk assessment

Load segregation based on IMDG Stowage rules Movement of vehicles on site will be coordinated by the Veolia Site Supervisor.

EMP – Draft001 41

7.4 Transport Route Assessment and Selection

The material for export will be packed into U.N. approved packaging and secured into shipping containers. All Transfrontier Shipment Documents (TFS), Dangerous Goods Declarations, Packing Lists will be completed by the Veolia Site Supervisor on behalf of the Notifier, as may be required. Veolia will label the packed containers in full accordance with the requirements of the IMDG Code. A route from the site to the port has been selected based on least risk. All containerized loads will be transported directly to port following project transport rules including an escort vehicle with an emergency response/coordination capability. It is our intention to load containers onto vessels which are registered in an EU country or in another country with similar high levels of seaworthiness certification. Once a booking has been confirmed Veolia will notify DEA of the name of the vessel and expected routing / voyage duration.

Transport route comparison: The various route options for transporting the pesticides from Holfontein to Durban harbour have been included in Annex 8. The trip has been broken down into three sections for ease of description. Section 1: Holfontein to N3 Holfontein is linked to the N12 by approximately 4km of single lane road. This road is used by all the heavy duty vehicles transporting hazardous waste to the landfill site and there is no suitable alternative option to this route. The N12 is a good quality secondary highway that runs from the Holfontein area directly to the Eastern bypass which then feeds onto the N3 highway. The N12 is a good quality highway and the alternative to this is a network of roads with many different intersections that would not be suitable for transport of the waste. Section 2: N3 Gauteng to Outside Durban The N3 from Gauteng to Durban is a dual carriageway toll road that is well maintained and covered by emergency services and has cell phone coverage its entire length. There are no suitable alternatives to this route. The toll operator (Tolcon) has been notified of the project and they have supplied contact details for the relevant incident response people. Veolia will notify Tolcon when the waste is to be transported to Durban. There are a number of areas where drivers would need to take extra care. These are highlighted on the maps but include the road coming down Van Reenan‟s pass where drivers need to obey the signs and engage low gears and keep to speed limits. There are arrester beds on this hill in case of emergency. The other area is coming down Town Hill just outside

EMP – Draft001 42

Pietermaritzburg (also engage low gear and stick to speed limits) as well as the route though Pietermaritzburg where the road can be quite busy. Section : N3 Offramp to Harbour Preferred option: There are a number of route options once the vehicles get into the greater Durban area. The first (and preferred option) is to take the M7 freeway off the N3 in the Pinetown area and follow this route into the South Durban industrial area (the M7 becomes Edwin Swales). The route then proceeds directly to the docks and is the road that most containerised traffic follows into the harbour area. The point of concern on this route is that it passes a school on Edwin Swales drive, however, this is a straight section of road and the vehicles would pass the area in a matter of minutes. Second option: This option involves staying on the N3 until reaching the N2 interchange. From there head South on N2 highway for approximately 5km and then turn off onto Edwin Swales drive and follow the route described above. This road will still pass the school. This route was relegated to the second option as the N2/N3 interchange area can be quite congested and the route along the M7 is lightly more direct. Unsuitable option: This route involves following the N3 into the center of Durban and then following the road along the beachfront to the docks. This route passes multiple businesses and traffic is normally slow.

EMP – Draft001 43

8 Workplan/Timescale

Following peer review and approval of this EMP document site work can commence to carry out the repackaging and sampling of waste stored at the two sites. Upon completion of the laboratory analysis and following approval of the Transfrontier Shipment (TFS) Notification document loading transportation and disposal can be completed. Accordingly it is anticipated that the site work will be split into two phases with a delay whilst the analysis is undertaken. The anticipated programme is as follows:


Submission of draft EMP by Veolia – up to 26/02/10

Peer review and No Objection to EMP – up to 16/11/10

Transfrontier Shipment Documentation

Submission of DRR to UK Environment Agency by DEA – up to 28/01/10

Approval of DRR by UK Environment Agency – up to 15/03/10

Submission of TFS Notification by DEA – up to 11/06/10

Approval of TFS by UK Environment Agency – up to 05/07/10

Site Work and Analysis

Repackaging and sample collection 12/04/10 – 15/05/10

Sample analysis 01/05/10 – 07/06/10

Loading and transportation to Durban 15/12/10 – 14/01/11.

International Transport & Disposal

Sea Freight to disposal site – up to 25/02/11

Disposal and reporting – up to 30/04/11

See Draft Program below:

EMP – Draft001 44

DEA Obsolete Pesticide Disposal Project 2010 Provisional timetable

ACTIVITY Time Jan Feb Mar Apr May Jun Jul Aug Sep Oct

Nov Dec Jan Feb Mar

EMP

Draft Issued for Peer Review & No Objection 26-Feb

Peer Review Approval by DEA 9months

No Objection from WB 1 week

Transfrontier Notification Documentation

Submission of DRR to UK EA 2 weeks

Approval of DRR by UK EA 2 weeks

Submission of TFS Notification by DEA) 1 month

Approval of TFS Notification by UK EA 1 month

Site Work & Analysis

Mobilisation of Equipment and Materials 6 weeks

Phase 1 - Repackaging & sample collection 3 weeks

Sample Analysis 6 weeks

Phase 2 – Loading & Transport to Durban 2 weeks

International Shipment & Disposal

Sea Freight to UK 4 weeks

Disposal 8 weeks

Reporting 2 weeks

EMP – Draft001 45

9 M&E

Monitoring and evaluation of the project activities will be carried out by DEA under established project arrangements. This will include site visits to confirm that necessary environmental protection measures are in place. The final monitoring plan will be developed once the EMP has been received from the

contractor. The Monitoring plan will be based on the activities specified in the EMP. However,

in broad terms the following aspects of the implementation of the EMP will be monitored:

1. Separation of non hazardous chemicals from hazardous.

2. Storage of the Limpopo /Wagtail stocks

Condition of the containers

Leakages or spillages

Emergency response procedure availability.

3. Sorting and repackaging of the stocks

Detailed inventory available

Internationally approved containers for transport

Compatibility of chemicals stored together.

Medical and emergency response available through out the route.

Containers must be clearly marked

4. Transport of the stocks to the shipping port

In line with appropriate legislative requirements. This would include SANS 10228 (Id and Classification), 10229 (Packaging for transport), 10233 (IBC‟s) and 10265 (labeling) as well as legislation specified in the TOR.

Compliance with Basel Convention requirements

Consultation with affected communities on route.

Communication and arrangements (emergency and other) with relevant local authorities on route.

Arrangements with National Road Agency (if necessary)

Monitor all risks identified in the EMP.

5. Temporary storage at the port (if applicable/required) and shipment

Arrangements with port authorities

Basic Assessment authorization (R 386 and FAO ToolKit (Vol 2D)

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