Catoni & Co Georgia Ltd

Transcription

1 ICMI CERTIFICATION SUMMARY REPORT Submitted to: International Cyanide Management Institute (ICMI) 1400 I Street, NW - Suite 550 Washington, DC UNITED STATES OF AMERICA 7 Dzebi Zubalashvilebi 0108 Tbilisi Georgia REPORT Report Number /A.0 Distribution: ICMI - 2 copies (1 pdf) - 1 copy (pdf) Golder Associates (UK) Ltd - 1 copy

2 Table of Contents 1.0 SUMMARY AUDIT REPORT FOR TRANSPORTATION LOCATION DETAIL AND DESCRIPTION OF OPERATION Facility Location Background... 1 SUMMARY AUDIT REPORT... 3 Auditors Findings... 3 s of Audit... 3 PRINCIPLE 1 TRANSPORT... 4 PRINCIPLE 2 INTERIM STORAGE... 9 PRINCIPLE 3 EMERGENCY RESPONSE i

3 1.0 SUMMARY AUDIT REPORT FOR TRANSPORTATION Name of Cyanide Transportation Facility:. Owner: Operator: Name of Responsible Manager: Address: State/Province: Country:.. Mr Vato Mgeliashvili 7 Dzebi Zubalashvilebi 0108 Tbilisi Georgia Tbilisi Georgia Telephone: Fax: - vato@catoni.com.ge 2.0 LOCATION DETAIL AND DESCRIPTION OF OPERATION 2.1 Facility Location Catoni & Co Georgia (CCG) transports sodium cyanide from the port of Poti in Georgia to the Gedabek mine in Azerbaijan. Catoni has a service agreement in place with the company Caloco who provide all drivers and vehicles. The solid cyanide cargo passes from Poti port to the Georgia-Azerbaijan border, a distance of 340 km. From the border to the mine site is a further 230 km. The mine site at Gedabek, Azerbaijan is the only certified mine site that Catoni currently supply. Each sea container holds a maximum of 20 boxes, each 1 ton. 2.2 Background CCG is part of a group of companies called the Catoni Group that operates in six countries Turkey, Iraq, Georgia, Azerbaijan, Bulgaria and Romania. Transport is the dominant activity within the group. CCG became a Signatory to the Code in May Catoni has a service agreement in place with Caloco who provide all drivers and vehicles. Caloco supply drivers, vehicles and provide maintenance of the vehicles as part of this service. The service level agreement states that Caloco must operate in accordance with the cyanide code. All Caloco staff involved in cyanide transportation are trained by Catoni before being allowed to commence cyanide transportation activities. Before the cargo leaves China (point of manufacture), Catoni obtain all necessary documentation to obtain permission from Ministry of Defence in Georgia for transit. As soon as Catoni are notified that a cargo will arrive in Poti port planning for the transportation of each consignment commences as follows: 13 1

4 The route is chosen (there is only one route that Catoni can use that utilises main roads); The weather forecast is checked; The road conditions are checked; and A suitable date to receive the goods for smooth operations is negotiated with the receiver at the mine. The Journey Manager is responsible for arrangement, control and tracking of vehicles and drivers in accordance with Catoni s Journey Management Plan. Catoni send an average of ten containers per consignment and the trucks to be used are selected taking the following into account: All drivers must be ADR dangerous goods certified; Check lists for each truck/trailer are compiled and completed prior to commencement; and Each driver must have passed a basic first aid course. Each driver must have a mobile phone with Georgian and Azerbaijan sim. The Journey Manager is the single contact point for Catoni during the convoy. They coordinate all activities with Catoni s Operations Manager. The Journey Manager is also responsible for regularly checking vehicles and drivers and ensuring that they are in compliance with CCG standards. The Journey Manager will also report all incidents, accidents and near misses to Catoni management. They shall also participate in risk assessments, emergency drills and exercises and participates in Catoni contractor audits and accompanies Catoni staff during their visit. Drivers stop after 340 km of the journey has been completed (near Tbilisi), and the loads and trucks are checked for safety. When the checks are complete, and if all is well, the journey to the final destination, a further 230 km way, continues after an overnight stop. 13 2

5 SUMMARY AUDIT REPORT Auditors Findings The International is: in substantial compliance with Cyanide Management Code Audit Company: Audit Team: Golder Associates Dale Haigh, Lead Auditor and Technical Specialist s of Audit The Certification Transport Audit was undertaken from April I attest that I meet the criteria for knowledge, experience and conflict of interest for Code Verification Audit Team Leader, established by the International Cyanide Management Institute and that all members of the audit team meet the applicable criteria established by the International Cyanide Management Institute for Code Verification Auditors. I attest that this Summary Audit Report accurately describes the findings of the verification audit. I further attest that the verification audit was conducted in a professional manner in accordance with the International Cyanide Management Code Verification Protocol for Cyanide Transportation Operations and using standard and accepted practices for health, safety and environmental audits

6 PRINCIPLE 1 TRANSPORT Transport Cyanide in a Manner that Minimizes the Potential for Accidents and Releases Transport Practice 1.1: Select cyanide routes to minimize the potential for accidents and releases. The operation is in substantial compliance with Transport Practice 1.1 The operation is Transport Practice 1.1; select cyanide transport routes to minimize the potential for accidents and releases. Catoni has developed and implemented a procedure (Cyanide Safety Management Plan) for the selection of transport routes that minimises the potential for accidents and releases or the potential impacts of accidents and releases. This procedure sets out the details to be followed, which includes a requirement to develop a road risk assessment (known as a Road Assessment), prior to each convoy commencing and this is updated after every convoy, allowing any new information to be provided for the next convoy. Catoni implements a procedure to at least annually re-evaluate the risks of the selected cyanide transport route and takes measures necessary to manage these risks. Route changes are not practical given the limited number of routes available between Poti and the mine site (with good road conditions). However, changes to conditions along the each route may result in instructions to modify operations. Catoni s procedure includes a requirement to complete a new risk assessment (known as a Road Assessment) at least annually. One example of these revisions was reviewed during the audit. Drivers are briefed on a regular basis (at the start of every consignment and at the start of each day during the two-day convoy) and warned of changes in route conditions (speed limits, construction work, etc.). Journey leaders also advise Drivers of hazards ahead so they may take appropriate action. Catoni has to obtain specific permission from the Georgian Ministry of Internal Affairs and from the Ministry of Defence before each cyanide transportation takes place. As the route is via Azerbaijan, the State Agency in Azerbaijan is also informed and provided with the pertinent information. Catoni subcontracts the transport of cyanide to Caloco. A Service Level Agreements is in place between Catoni and Caloco and is signed by the Managing Directors. Included within the Service Level Agreements is the requirement for ICMC compliance. Transport Practice 1.2: Ensure that personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment. The operation is in substantial compliance with Transport Practice

7 The operation is Transport Practice 1.2; ensure that personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment. Catoni only uses trained and competent operators to operate its vehicles. There is a requirement in Georgia/Azerbaijan for drivers to be licensed for HGV vehicles and for dangerous goods transport. Catoni holds a record of all drivers used (Driver Certification Control Form) which provides details of the Driving Licence, Proficiency Licence, Competency Assessment (by Catoni) and ADR certificate. This summary list provides easy identification of when drivers are in or not in date with these requirements. Catoni also has a training scheme to ensure that all drivers are competent. Drivers are also provided with a range of cyanide awareness and handling training. Catoni maintains a record of the training provided to personnel within a matrix. Prior to starting a convoy, the Journey Manager reviews the drivers that have appropriate licence and training which are in date and a number are selected for the convoy. Catoni also maintains copies of the files on drivers used by its subcontractors. Caloco staff and Journey Managers were interviewed about their knowledge of the procedures and practices involving cyanide and provided good responses indicating effective knowledge and experience. Transport Practice 1.3: Ensure that transport equipment is suitable for the cyanide shipment. The operation is in substantial compliance with Transport Practice 1.3 The operation is Transport Practice 1.3; ensure that transport equipment is suitable for the cyanide shipment. Catoni only use equipment designed and maintained to operate within the parameters of the cyanide loads it will be handling. Cyanide manufacturers and suppliers limit the mass of cyanide containers sent to Georgia/Azerbaijan to around 22 tonnes. This was clearly shown on the chain of custody information provided with each shipment. Equipment used to transport cyanide loads consists of road vehicles (tractor units and trailers) that were purchased to a design specification appropriate for the cyanide transport task. These include main tractors with articulation and trailers which are 12 m in length. On loading at the port, chain of custody information is provided to Catoni setting out the load weights and weighbills are provided to each driver. No transfer of cyanide containers to other trailers is undertaken in the Caloco yard. Catoni/Caloco have registration certificates for the tractors and trailers which show that the maximum trailer loading capacity is significantly above the 22 tonnes required. However, the load carried is restricted by the loading capacity allowed on roads which is 44 tonnes in Georgia and Azerbaijan which is still above the 22 tonne cyanide load weight. 13 5

8 Catoni maintains records of vehicle specifications. Maintenance history is shown in vehicle log books kept with each vehicle. At the start of each convoy, the Journey Manager checks that the trailers are only carrying cyanide. Prior to the start of each convoy and during the convoy, loads are checked by the drivers and any issues identified are reported to the Journey Manager. Caloco carries out maintenance of vehicles (including tractor and trailer) on a regular basis. There are procedures for loading trucks and containers to ensure that those loads are not exceeded (no other goods are transported on cyanide vehicles). Catoni has stated in training that a maximum of 20 boxes, each 1 ton, are laden in the sea container, hence each sea container should not normally exceed 22 tons, and weights over legal limits are not accepted. Transport Practice 1.4: Develop and implement a safety program for transport of cyanide. The operation is in substantial compliance with Transport Practice 1.4 The operation is Transport Practice 1.4; develop and implement a safety program for transport of cyanide. Catoni s procedures state that HGVs should be equipped with a suitable load securing equipment and that for containers this should include twist locks. This is checked prior to the start of each convoy and is recorded in the HGV Check lists. Seals are re-checked each day. The convoy transport system, with routine stops, check-ins and Journey Manager oversight further ensures the integrity and protection of the containers. The Road Assessment (i.e. road risk assessment) provides further assessment and guidance of road conditions and preventative measures that should be adopted. At the mine, the chain of custody document is signed after inspection to acknowledge receipt of the container in a good condition. As all cyanide is delivered by sea to the port at Poti in Georgia. Containers arrive with placards already in place as attached by the supplier, in accordance with the International Maritime Dangerous Goods (IMDG) Code. These placards remain on the containers until the containers are unpacked at the mine sites. These provisions and the attachment of the International Maritime Organisation (IMO) marine pollutant label ensure that all consignments comply with international standards. The placards used on containers, include: UN Numbers; and Hazchem classification. These signs are displayed on all four sides of the container. The presence of each sign is checked at the port and at during the journey. 13 6

9 Catoni has a safety program in place which includes vehicle inspection by Caloco, a maintenance program implemented by Caloco, limitation on driving hours and safety procedures. 13 7

10 Transport Practice 1.5: Follow international standards for transportation of cyanide by sea and air. The operation is in substantial compliance with Transport Practice 1.5 The operation does not involve shipment by sea or air and so Transport Practice 1.5 does not apply. Transport Practice 1.6: Track cyanide shipments to prevent losses during transport. The operation is in substantial compliance with Transport Practice 1.6 The operation is Transport Practice 1.6; track cyanide shipments to prevent losses during transport. Vehicles transporting for Catoni have several means to communicate with Catoni, with emergency responders and with the relevant mining operation. Each driver within the convoy has a mobile phone with two Sim cards for Georgia and Azerbaijan. Telephone numbers are provided at the start of the convoy (the transport company, the mining operation, the cyanide distributor, emergency responders, Journey Managers and other drivers) so drivers can get in touch with relevant persons. There are no black spots for the GPS or mobile phone system for the routes that Catoni is currently involved with. All vehicles transporting cyanide are fitted with GPS but are not actively tracked. Catoni s prestart checklists include checking the details of the communication equipment. Emergency response guidance and contact information is carried in the convoy. In the event of an emergency, drivers telephone Catoni (Journey Manager). The potential for communication blackout areas along transport routes have been assessed (from road trips) and none have been identified in the routes that Catoni use. Prior to the shipment, plans are developed to estimate the timing of the convoy between the pick-up point at the port (Poti) and the mine. Shipping records are obtained by Catoni at the port (Poti). This chain of custody information details the amount of cyanide in transit with one sheet for each container. Shipping documents are included as part of every consignment. 13 8

11 PRINCIPLE 2 INTERIM STORAGE Design, Construct and Operate Cyanide Trans-shipping Depots and Interim Storage Sites to Prevent Releases and Exposures. Interim Storage Practice 2.1: Store cyanide in a manner that minimizes the potential for accidental releases. The operation is in substantial compliance with Interim Storage Practice 2.1 The operation is Transport Practice 2.1 as no interim storage is undertaken by Catoni the principal is not applicable. 13 9

12 PRINCIPLE 3 EMERGENCY RESPONSE Ensure that Process Controls are Protective of the Environment. Emergency Response Practice 3.1: Prepare detailed emergency response plans for potential cyanide releases. The operation is in substantial compliance with Emergency Response Practice 3.1 The Emergency Response Plan is an integral part (Part 3) of the Cyanide Safety Management Plan created by Catoni. The document covers both Catoni and its subcontractors. This is the document to be used in the event of an emergency involving Sodium Cyanide. The document has the following sections; Cyanide Emergency Response, Emergency Response Phone Numbers, Emergency Roles and Responsibilities, Emergency Response and Incident Investigation Workflow, Prompt Cards (detailing the action to be taken in Emergency Scenarios Traffic Accident, Fire at the Vehicle, Spill, Poisoning). In addition, there are Road Assessments for the route, which are also specified in the Cyanide Safety Management Plan and detail the risks associated with the route and how they should be managed. The Cyanide Safety Management Plan considers the physical and chemical form of the cyanide and states the labelling requirements must follow those required by ADR Regulations and include Sodium Cyanide (solid) hazard class and Sodium Cyanide (solid) danger and UN number. The Emergency Response Plan states that the procedures aim to provide guidance and information and to organise people involved for actions to be taken in emergencies during transportation of solid sodium cyanide on public roads. The descriptions of key roles in the event of an accident detailed in the Cyanide Procedures relate only to personnel involved in road transport. The Catoni General Manager is the primary response for incidents on the road. Emergency numbers are also listed in the Emergency Contact list within the Emergency Plan. The plans states that the Catoni General Manager shall ensure that copies of Catoni s emergency response procedures are distributed to all relevant parties involved such as governmental agencies, police, hospitals, fire departments and emergency responders in order for safe and efficient emergency response coordination between those parties. It is noted that in Georgia and Azerbaijan, response to emergency actions must only be carried out by Emergency Responders and so Catoni s role is limited to contacting these authorities and keeping a safe distance from the incident

13 Emergency Response Practice 3.2: Designate appropriate response personnel and commit necessary resources for emergency response. The operation is in substantial compliance with Emergency Response Practice 3.2 The operation is Transport Practice 3.2; designate appropriate response personnel and commit necessary resources for emergency response. Catoni s HSEQ policy states that each Catoni business unit will provide appropriate training for all staff to enable them to carry out their work in a safe manner. Caloco staff (including drivers and managers), the Journey Manager, Drivers and Catoni staff involved in Cyanide Transportation activities are all trained by Catoni. Training courses provided by Catoni include the following Cyanide Emergency Response Plan awareness, Cyanide Safety Management Plan awareness, Cyanide Environment & Social Performance Plan awareness, Near Miss, Incident/Accidents Reporting awareness. Training events are logged in training forms retained by Catoni and within the Training matrix held by Catoni. Catoni undertook the above training for drivers on 14 and 16 March Catoni staff were provided with the same training in December Interviews were conducted with Catoni and Caloco staff. This demonstrated that personnel operating cyanide transport equipment are appropriately trained and had a good understanding of what to do in the event of an emergency. The Cyanide Safety Management Plan (Procedure) identifies the key roles and responsibilities in the event of an emergency for the following positions: Emergency Response Coordinator; CCG General Manager; Contract Journey Manager; and Drivers. Specific duties are also stated within the procedure for each emergency scenario considered. Emergency response equipment is taken in each vehicle during each journey. The equipment is listed in CNOP003 PPE & Vehicle Emergency Equipment Requirement. The HGV checklist used to check vehicles prior to commencement of all journeys involving cyanide also lists the emergency equipment used. Examples of the completed forms were provided for three example journeys. The form is signed by the Driver and provided to the journey manager. The Training Plan states how long each training program is valid and so refresher training is required before the end of this duration. For the Emergency Plan this is stated as every 2 years. In addition there is a service level agreement between Catoni and Caloco stating that it is in place to ensure cyanide is transported in a safe and environmentally sound manner and in accordance with all applicable statutory and regulatory requirements

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15 Emergency Response Practice 3.3: Develop procedures for internal and external emergency notification and reporting. The operation is in substantial compliance with Emergency Response Practice 3.3 The operation is Transport Practice 3.3; develop procedures for internal and external emergency notification and reporting. The Cyanide Safety Management Plan (Procedure) details specific responsibilities for certain roles as follows: Emergency Response Coordinator (ERC, Catoni personnel), coordinates with Catoni General Manager and senior management, all external emergency services who need to be contacted depending on the type of emergency, drivers and insurers; CCG (Catoni) General Manager (Catoni personnel), contacts the ERC and Catoni Senior Management; Journey Manager (Caloco personnel), contacts the drivers and the ERC; Drivers (Caloco personnel) contact the Journey manager and liaises with all external emergency services as required. The Emergency Plan also details an Emergency Response and Incident Investigation Workflow which sets out who should be contacted and at what stage. This includes the contacts identified above but also includes commencing and investigating and contacting the client about the incident. The relevant contact details for parties identified are provided in the prompt card for each emergency scenario detailed within the Cyanide Safety Management Plan (Procedure). All emergency services (fire, ambulance, police, emergency services, and rescue & evacuation) share the same national telephone contact number (112). There is therefore no specific need to contact these organisations via a separate telephone number. In addition, the governmental process in Georgia is such that involvement with regional emergency services is completed by the Ministry of Internal Affairs once documentation is provided by Catoni and approval given by the Ministry. This process is the same in Azerbaijan where the State complete this communication with other stakeholders. Catoni has to obtain specific permission from the Georgian Ministry of Internal Affairs and from the Ministry of Defence before each cyanide transportation takes place. As the route is via Azerbaijan, the State Agency in Azerbaijan is also informed and provided with the pertinent information. Hospitals in possession of cyanide anti dote kits have been identified and a list of those hospitals have been included in the Cyanide Safety Management Plan. The list of hospitals will be reviewed & updated at least once per year during routine review process of CCG Cyanide Safety Management System

16 Emergency Response Practice 3.4: Develop procedures for remediation of releases that recognize the additional hazards of cyanide treatment chemicals. The operation is in substantial compliance with Emergency Response Practice 3.4 The operation is Transport Practice 3.4; develop procedures for remediation of releases that recognize the additional hazards of cyanide treatment chemicals. The Cyanide Safety Management Plan (Procedure) states that the use of chemicals such as sodium hypochlorite, ferrous sulfate and hydrogen peroxide to treat cyanide is prohibited. Emergency responders must be advised so as to avoid use of such chemicals to treat cyanide that has been released into surface water. The procedure includes details to follow in the event of a cargo spill which are as follows: Call fire department / traffic police, inform them about the spill accident. Inform officers about the cargo and its potential hazards. Give specific name of the cargo as stated on transport documents; Never put yourself at unnecessary risk. Move towards upwind direction and keep distance of at least 200 meters for minor spills, 1.3 km for large spills; and Never attempt to collect or contain spillage by yourself. Toxic gases from sodium cyanide may have fatal effects when breathed. In Georgia and Azerbaijan, responding to emergencies involving hazardous chemicals are the responsibility of the emergency services. The Cyanide Safety Management Plan (Procedure) states that the use of chemicals such as sodium hypochlorite, ferrous sulfate and hydrogen peroxide to treat cyanide is prohibited. Emergency responders must be advised so as to avoid use of such chemicals to treat cyanide that has been released into surface water. Emergency Response Practice 3.5: Periodically evaluate response procedures and capabilities and revise them as needed. The operation is in substantial compliance with Emergency Response Practice 3.5 The operation is Transport Practice 3.5; periodically evaluate response procedures and capabilities and revise them as needed. There are provisions for periodically reviewing and evaluating the adequacy of the Cyanide Procedures and they have been and will continue to be implemented. The Cyanide Procedures are currently on Revision 00 dated 12 December The procedure states that the Catoni COO will review the procedure

17 The Cyanide Procedures revision table details the date of publication, new revision number and a description of the revision. Other related procedures are also updated by Catoni. There are provisions for periodically conducting mock emergency drills and they have been and will continue to be implemented. The Cyanide Safety Management Plan (Procedure) states (section 3.6) that Catoni should run regular drills. The plan goes on to suggest that the following drills will be conducted over the next 2 years: Traffic accident / vehicle collision; Fire at vehicle; Minor Spill; and Medical emergency. A mock drill was completed on 30 May The exercise assumed a traffic accident emergency at the Caloco site. Four Caloco drivers and managers were in attendance and the exercise was reviewed by Catoni. Drivers demonstrated that actions required during emergency scenario. Details of the response were recorded by Catoni. There is a procedure to evaluate the performance of the ERP after its implementation and this has been and will continue to be followed

18 Report Signature Page GOLDER ASSOCIATES (UK) LTD Dale Haigh Lead Auditor/Transportation Technical Specialist Sophie Wheeler Project Manager/Reviewer : 13 DH/EP/SW/ Company Registered in England No At Attenborough House, Browns Lane Business Park, Stanton-on-the-Wolds, Nottinghamshire NG12 5BL VAT No Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

19 Golder Associates (UK) Ltd Cavendish House Bourne End Business Park Cores End Road Bourne End Buckinghamshire SL8 5AS UK T: [+44] (0)