ICMI Implementation and Auditing Tailings Deposition and the Cyanide Code Presented by Callie Nieuwoudt

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1 ICMI Implementation and Auditing Tailings Deposition and the Cyanide Code Presented by Callie Nieuwoudt

2 Fraser Alexander Tailings overview. A holistic approach to mining residue Fraser Alexander Tailings provides a world-class service in the deposition of mining residue into safe environmentally-friendly tailings dams. These tailings dams are often considered a valuable resource and good management is required to ensure that they are well maintained. Our holistic approach to re-mining and tailings deposition encompasses a complete environmental solution from conceptual design and effective dam operation to environmentally compatible closure of the tailings deposition facility or the possible re-mining of the dam. A comprehensive range of services We provide a comprehensive range of services, including the design, construction, operation and management of new tailings dams, as well as the re-mining of existing dams through hydraulic re-mining. Comprehensive environmental solutions are an essential part of our operations including rehabilitation, sewage and water treatment, environmental closure and monitoring of the tailings deposition facility. Our business areas From Fraser Alexander Pty (Ltd) inception almost a century ago, Fraser Alexander Tailings has evolved into a global player, committed to delivering effective risk management solutions in particularly wet tailings disposal, re-mining, environmental works, water treatment and related aspects.

3 Fraser Alexander Tailings Theatre of Operations South Africa, Namibia, Zimbabwe, Swaziland, Democratic Republic of the Congo, Zambia, Tanzania, Botswana, Ghana, Mali & Ivory Coast. Australia Chilli Also involved as consultants in Swaziland Armenia Canada Switzerland Philippines

4 Where it began. In 2008/9 Fraser Alexander Tailings were requested to become part of the ICMI compliance audits. The purpose was to assist our clients, the signatory companies to the Code, to proof compliance towards the Code on the Tailings Storage Facilities. With no previous exposure or knowledge of the Code, we worked together with representatives from the client companies whom had exposure to and knowledge of the Code. This lack of knowledge and understanding of the Code on our side, resulted in a whole new Risk management system, with supporting documents being created and developed. This system addressed all aspects of the code including, Production, Supply, Transportation, storage, to name but a few. By default this implied more documentation systems and processes to be implemented and managed, and these would require additional personnel to manage the systems and processes.

5 However, during the GAP audits, the following became evident: We are not involved in the production and supply of Cyanide. We are not involved in the Transportation of Cyanide. We are not directly involved in the storage of Cyanide. The GAP audits that were taking place in the Free state and Carletonville areas, enabled us as Fraser Alexander Tailings to understand the requirements of the Code, and support our clients to comply with the Code. Understanding the requirements of the Code, we as FAT were able to determine where each element of the Code fit into our existing 13 Element Risk Management System. We could also identify: Which documents in our system address the requirements of the Code: Whether these documents needed tweaking to align them with the Code and; Which documents are lacking in our system and needs to be developed.

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7 Alligning the Code with FAT SHEQ Management System 1. SHE Strategy SHEQ Policies and Procedures. Management Instructions. 2. Legal Requirements MHSAct Appointments and responsibilities. OHSAct Appointments and responsibilities. Legal Compliance. 3. Risk Assessments Change Management Procedure. Risk Assessments Addressing normal operations and related Cyanide exposure issues on the TSF. Continuous Risk Assessment. Mini Risk Assessment.

8 Alligning the Code with FAT SHEQ Management System 4. Training Client-, Cyanide-, SHEQ-, Site Specific Inductions. Written Task Procedures. Awareness training. PTO s and SBO s assessment tools. Competency Training. 5. Health Medical surveillance First Medical, Annual Medical, Special Medical, Exit Medical Occupational Hygiene Surveillance. 6. Personal Protective Equipment Issued with correct PPE for task and exposure. PPE evaluation. Care of PPE.

9 Alligning the Code with FAT SHEQ Management System 7. Emergency Preparedness Plan for emergencies Tailings Dam Failure model, Emergency Evacuation Procedures, Evacuation drills, Emergency Communication systems. 8. Inspections Visual, Daily, Weekly, Monthly, Quarterly and Annually. Monthly Reports and Quarterly Reports. Annual Stability Reports. 9. Communication SHE & Communication Meetings, Toolbox Talks, Awareness Topics. Client Communication topics and Client Meetings 10. Incidents Incidents Reporting and Investigation: Near Miss Incidents: Environmental. (Spills, Wildlife mortalities etc)

10 Alligning the Code with FAT SHEQ Management System 11. Environmental Management Wildlife monitoring & reporting on Mortalities. Environmental Awareness training and topics. 12. Sub-contractor Management Compliance to FAT and Client requirements. 13. System Performance Management Internal SHEQ Audits Monthly Site Self Audits. As you can clearly see, our Risk Management system made provision for all the elements of the Code These Cyanide Audits are actually also very useful to determine the effectiveness of the SHE System as a Independent External Auditor measure our level of compliance. The Auditors recommendations also assist in the continuous improvement of our current system.

11 Alligning the Code with FAT SHEQ Management System As you can clearly see, it became evident that our Risk Management system made provision for all the elements of the Code. It became a simple exercise of correctly identifying the evidence in our existing Risk Management system to satisfy the requirements as set out in the Code. Where the evidence did not fully satisfy the needs of the Code, documents, systems and processes were adjusted to conform to the Code requirements or new documents, systems or processes were developed. Being part of the ICMI Audits also have the following benefits for Fraser Alexander Tailings: The effectiveness of our current Risk Management system and our level of compliance is tested comprehensively. The Audit recommendations also assist in the continuous improvement of our existing Risk Management system. It also prompted us to bring in another level into the Site Risk Management role.

12 Site Structures In our effort to ensure customer satisfaction and compliance, we had to implement a better support structure on the Sites.

13 Fraser Alexander Tailings Succeses Harmony Gold Mining Company North Operations South Operations Goldfields Limited, South Africa Region KDC West Operations Beatrix 1 and 2 Operations Anglo Gold Ashanti, South Africa. VRO Operations West Wits Operations

14 In Conclusion The 13 Element Risk Management System that is used throughout Fraser Alexander Tailings is a effective and well entrenched system, that not only enable us to live our First Value: Never Compromise on Safety But also enables us to: Delight our customers. Deliver without excuses. Be innovative in our solutions. Comply with any Code, Standard or best practices.(icmi, ISO 9001, ISO 14001, OHSAS because.

15 In Conclusion We have a effective systems in place, it might need some tweaking here and there, inclusion of a statement or word, etc to address the specific issues of a code or a standard. At the end of the day all learning's are evaluated, assessed and where applicable incorporated into the Risk Management System as part of our Continual Improvement Strategy. This approach also assists Fraser Alexander Tailings to strengthen its position as a major role player in the Tailings Risk Management arena.

16 THANK YOU. ANY QUESTIONS?