OXIQUIM PERU SAC, BASE TRANSPORTATION, CALLAO, PERU
Transcription
OXIQUIM PERU SAC, BASE TRANSPORTATION, CALLAO, PERU
Combined Summary Audit Reports for Transport and Warehouse INTERNATIONAL CYANIDE MANAGEMENT CODE OXIQUIM PERU CALLAO, PERU SAC, BASE TRANSPORTATION, SUMMARY AUDIT REPORT FEBRUARY 2014 FEBRUARY 2014| OXIQUIM 1 Lead Auditor Signature INTERNATIONAL CYANIDE MANAGEMENT INSTITUTE Cyanide Transportation Operations Summary Audit Report For The International Cyanide Management Code and OXIQUIM PERU S.A.C. – Callao – Callao – Peru Verification Protocol www.cyanidecode.org February 2014 LIMA, PERU RIO DE JANEIRO, BRASIL FEBRUARY 2014| OXIQUIM 2 Lead Auditor Signature TABLE OF CONTENTS INTRODUCTION ..................................................................................................................................... 4 1 TRANSPORT .................................................................................................................................... 7 1.1 1.2 1.3 1.4 1.5 1.6 2 INTERIM STORAGE ..................................................................................................................... 16 2.1 3 TRANSPORT PRACTICE 1.1 ............................................................................................................ 7 TRANSPORT PRACTICE 1.2 ............................................................................................................ 9 TRANSPORT PRACTICE 1.3 .......................................................................................................... 10 TRANSPORT PRACTICE 1.4 .......................................................................................................... 12 TRANSPORT PRACTICE 1.5: ......................................................................................................... 13 TRANSPORT PRACTICE 1.6: ......................................................................................................... 14 TRANSPORT PRACTICE 2.1 .......................................................................................................... 16 EMERGENCY RESPONSE: .......................................................................................................... 17 3.1 3.2 3.3 3.4 3.5 TRANSPORT PRACTICE 3.1: ......................................................................................................... 17 TRANSPORT PRACTICE 3.2: ......................................................................................................... 18 TRANSPORT PRACTICE 3.3: ......................................................................................................... 19 TRANSPORT PRACTICE 3.4: ......................................................................................................... 20 TRANSPORT PRACTICE 3.5: ......................................................................................................... 21 FEBRUARY 2014| OXIQUIM 3 Lead Auditor Signature INTRODUCTION Information on the audited operation Name of Cyanide Transportation Facility: OXIQUIM PERU SAC Name of Facility Owner: OXIQUIM PERU SAC Name of Facility Operator: OXIQUIM PERU SAC Name of Responsible Manager: LESLIE LEMBCKE Address: Av. San Borja Norte 166 State/Province/Country: San Borja/Lima / Perú Telephone: +51 1 225-1346 Fax: (511) -------------- E-mail: leslie.lembcke@oxiquim.pe Aspects of the location and description of the operation: OXIQUIM the largest subsidiary of Sintex-is a closed corporation engaged in the manufacture of resins for the wood panel industry and industrial resins, distribution of chemical products for industry and mining, and warehousing services and cargo / unloading liquid bulk ships in its maritime terminals located in the bay of Quintero and Coronel. In addition, The Company specializes in the distribution of products for pulp mills, fish, paint, food, textile, leather, pharmaceutical, plastics, agriculture and mining, among others. OXIQUIM Peru S.A.C. consolidates and begins commercial operations in the city of Lima at the beginning of 2005. Since then, his work in the distribution and marketing of a wide range of chemicals focuses incursions and exceptional representation of foreign chemical companies. These activities are relate in a complementary and synergistic manner with the main office. OXIQUIM Peru SAC stored sodium cyanide in wooden presentation boxes for 1TM and 50 kg cylinders. • Box IBC (Intermediate Bulk Container). It is a removable wooden box, 1, 4 m3 containing a poly bag with attachable handles the electric hoist. Inside this bag is a polypropylene bag in direct contact with sodium cyanide briquettes. The IBC box has a capacity of up to 1 ton. • Cylinder Metal: A metal cylinder contains inside a polythene bag in direct contact with sodium cyanide briquettes. The cylinder has a capacity of 50 kg. Operation OXIQUIM Peru SAC includes controlling the Storage Distribution (Downloading cyanide packaging containers, packaging storage and loading cyanide cyanide to packaging containers made by your UNITRADE) and control Transportation management distribution (Warehouse UNITRADE, is the distribution warehouse Customer). These activities are performed for 09 years with ZERO (00) accidents. The store OXIQUIM Sodium Cyanide, is located at 8651 Av. Néstor Gambetta, Callao, owned by the company UNITRADE SA, in an area zoned for big industry "I-3". The surface water bodies closest to the land, are the Pacific Ocean, approximately 70 m to the west and the river Chillón 1.300 m north of the site. FEBRUARY 2014| OXIQUIM 4 Lead Auditor Signature SUMMARY AUDIT REPORT FOR CYANIDE TRANSPORTATION OPERATIONS Instructions 1. The basis for the finding and/or statement of deficiencies for each Transport Practice should be summarized in this Summary Audit Report. This should be done in a few sentences or a paragraph. 2. The name of the cyanide transportation operation, lead auditor signature and date of the audit must be inserted on the bottom of each page of this Summary Audit Report. 3. An operation undergoing a Code Verification Audit that is in substantial compliance must submit a Corrective Action Plan with the Summary Audit Report. 4. The Summary Audit Report and Corrective Action Plan, if appropriate, for a cyanide transportation operation undergoing a Code Verification Audit with all required signatures must be submitted in hard copy to: International Cyanide Management Institute (ICMI) 1400 I Street, NW, Suite 550 Washington, DC 20005, USA 5. The submittal must be accompanied by 1) a letter from the owner or authorized representative which grants the ICMI permission to post the Summary Audit Report and Corrective Action Plan, if necessary, on the Code Website, and 2) a completed Auditor Credentials Form. The lead auditor’s signature on the Auditor Credentials Form must be certified by notarization or equivalent. 6. Action will not be taken on certification based on the Summary Audit Report until the application form for a Code signatory and the required fees are received by ICMI from the applicable cyanide transportation company. 7. The description of the cyanide transport company should include sufficient information to describe the scope and complexity of its operation. FEBRUARY 2014| OXIQUIM 5 Lead Auditor Signature Auditor’s Finding This Operation is: X in full compliance The International Cyanide Management Code in substantial compliance not in compliance with the International Cyanide Management Code. No significant cyanide incidents or exposures and releases were note as occurring during the audit period. Audit Company: ISOSURE SAC | JMAQ Audit Team Leader: Julio C. M. Monteiro E-mail: jmaq@ig.com.br / auditoria@iso-sure.com Date(s) of Audit: December 2014 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 conduct 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. Name and Signatures of Other Auditors Name Position Signature Date Julio Monteiro Lead Auditor / Production Technical 20 December 2014 Carlo Vargas Auditing Assistance 20 December 2014 FEBRUARY 2014| OXIQUIM 6 Lead Auditor Signature Verification Protocol 1 TRANSPORT Transport cyanide in a manner that minimizes the potential for accidents and releases. 1.1 TRANSPORT PRACTICE 1.1 SELECT CYANIDE TRANSPORT ROUTES TO MINIMIZE THE POTENTIAL FOR ACCIDENTS AND RELEASES. X in full compliance with The operation is in substantial compliance with Transport Practice 1.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.1 requiring an operation Select cyanide transport routes to minimize the potential for accidents and releases. The OXQUIM Peru SAC (Hereinafter OXIQUIM) operation for the transport and storage of sodium cyanide was subject to an audit. The Auditor was verifies and all questions related to the transport protocol ICMI were answered. OXIQUIM has the procedure for the Transport of Sodium Cyanide, whose goal is to transport sodium cyanide, without causing damage or injury to persons and / or the environment and the preservation of substances transported from UNITRADE (Distribution Warehouse OXIQUIM contracted) to the point set by the client. All activities associated with Transport Practice 1.1 are performer by companies’ certified by ICMI OXIQUIM designated by the carrier for the transportation service conducts an annual review of the criteria used for evaluation of the route to: traffic density, cities, bridges, canals, road conditions, route design (curves, berms, number of lanes), altitude, crossroads, detours, weather conditions and the socio-political conditions complying with the provisions of the Code. In the evaluation report route was identify as a major risk: Urban areas, high traffic, speeding vehicles, winding road (characteristics of the Peruvian geography), and transport of other dangerous goods. FEBRUARY 2014| OXIQUIM 7 Lead Auditor Signature OXIQUIM states that in conjunction with the Transport Company must conduct the evaluation of the route prior to the first transport to a customer base or annual basis by the Chief Security Officer Security or the Transportation Company and Chief operations. OXIQUIM states that in conjunction with the transport company must conduce the evaluation of the route prior to the first transport to a customer base or annual basis by the Safety Officer or Safety Manager of the carrier and a Chief operations OXIQUIM cyanide. The evaluation of the route will be regularly update by the carrier OXIQUIM and find new de Cyanide of the OXIQUIM. The evaluation of the route will be regularly by the carrier OXIQUIM and to find new significant hazards or risks the trip report to be present at the end of each of the customer service. NOTE if check blind spots in the path analysis, they will be assess as a danger the safety and the driver will provide the necessary communications equipment to maintain communications throughout the route. Technical stops, Fire Stations and Hospitals or Medical Centers in the area, as well as phone and contacts. This activity is perform in company representative who hires OXIQUIM companies to transport sodium cyanide, which are certify by the ICMI. It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA LOGISTICS and EDEWIT. OXIQUIM, identify the Major bridges, tolls, to consumption Fuel Stops and Points of Techniques stops, Fire Stations and Hospitals or Clinics Zone, ASI COMO Also Telephones and Contacts. This activity is in Company Performs Representative Companies That Hire For Transportation Of OXIQUIM sodium cyanide which if they are certified by the ICMI. The existence of letters sent to the fire companies and medical centers to communicate their roles in case of any emergency and open communication channels between OXIQUIM and emergency support centers were check. Each of the support centers that are consider in the Emergency Plan OXIQUIM sealed these. Among the letters were consider emergency support centers (fire companies and medical centers) near OXIQUIM and routes used by carriers hired by OXIQUIM. For the transport of sodium cyanide OXIQUIM asks its carriers have a control room also carriers with GPS system continually provide the positioning of each of the vehicles at all times. As well as continuous speed supervision at each point of the route from the starting point to the end then this information delivered to the Safety Officer OXIQUIM. FEBRUARY 2014| OXIQUIM 8 Lead Auditor Signature OXIQUIM also establishes specifications using trucks escort during the transit of sodium cyanide being due to use ONE (01) escort van for every three (03) or fewer units of traffic load. Only you can upload ONE (01) Container for each platform and can only drag a wagon chassis. The convoy may include one or more escort vehicles at your request. Convoy displacement is dependent on weather conditions; Convoy Leader evaluate the safety of the route in each case, may stop the convoy if satisfied that the conditions do not allow safe travel. After each trip, the convoy leader must serve the "Trip Report" where findings that compromise safety during transport they are included within the assessment route for modification evidences. OXIQUIM information given (MSDS, emergency record and record of product information) to support emergency centers (health centers and fire companies) along the above routes, evidenced by a letter signed and received with such information. This activity is carry out for external support centers could be prepare for emergencies. In addition, external support centers comments are ask to manage risk as a way to query and get feedback. When OXIQUIM carrying sodium cyanide, the control room of Transport, continuously provide the positioning of each of the vehicles at all times, as well as continuous monitoring of the velocity at each point of the route. This control done through geofencing these indicate the maximum and minimum speed of the train each way along the route based on information provided by the roadmap Site www.cyanidecode.org. 1.2 TRANSPORT PRACTICE 1.2 ENSURE THAT PERSONNEL OPERATING CYANIDE HANDLING AND TRANSPORT EQUIPMENT CAN PERFORM THEIR JOBS WITH MINIMUM RISK TO COMMUNITIES AND THE ENVIRONMENT. X in full compliance with The operation is in substantial compliance with Transport Practice 1.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: OXIQUIM procedure establishes minimum requirements for drivers: health, legal, defensive driving training, emergency response training with sodium cyanide (spills and poisoning prevention). FEBRUARY 2014| OXIQUIM 9 Lead Auditor Signature OXIQUIM establishes criteria for the evaluation of the route to: traffic density, cities, bridges, canals, road conditions, route design (curves, berms, number of lanes), altitude, intersections, detours, weather conditions and the socio-political conditions. OXIQUIM states that transport companies that hires must use the criteria thereof which are audited by OXIQUIM annually as a result of the audit verifies that carriers comply with the standards set OXIQUIM by the same audit OXIQUIM evidence carriers use trained, qualified and licensed operators to operate their vehicles. In the same way, it is evident that all staff and transport equipment are in a position such that the possibility of cyanide releases and exposures are minimize. OXIQUIM, Shop Distributive UNITRADE in Callao, each year all staff (the warehouse and transport) has to go through different types of training, including new staff from scratch. There is a matrix for training. They are divide into sections for safety and routine work. Special training is carry out by the fire department and external entities specialists. OXIQUIM has a special department within Human Resources to develop, implement and verify these workouts. OXIQUIM has staff trained in safe handling and storage of sodium cyanide, the Annual Training Program 2014, in which training for warehouse staff and people of Transportation Companies evidenced, was evident. In addition, he proceeded to interview two (02) equipment operators in operations management and storage of sodium cyanide. The OXIQUIM does not subcontract handling Storage Operation, however is subcontract the Transport Operation Practice 1.1 are performed by ICMI certified Transportation Company according publication in the ICMI. Site www.cyanidecode.org 1.3 TRANSPORT PRACTICE 1.3 ENSURE THAT TRANSPORT EQUIPMENT IS SUITABLE FOR THE CYANIDE SHIPMENT. X in full compliance with The operation is in substantial compliance with Transport Practice 1.3 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.3 requiring an operation Ensure that transport equipment is suitable for the cyanide shipment. OXIQUIM states that Transport Companies hired must have a maintenance procedure and planning of it, this requirement is audit by the Safety Officer OXIQUIM annually according to the program without warning. OXIQUIM also states that hire companies FEBRUARY 2014| OXIQUIM 10 Lead Auditor Signature must meet the requirements of ICMI and the Ministry of Transport and Communications (MTC) of Peru. OXIQUIM states that vehicles will be hired lowboy trailers with a maximum load capacity of 22 tons, which are certify to transport sodium cyanide by the Peruvian government. In addition, before each trip OXIQUIM staff verifies that vehicles are fit to travel and meet the requirements described above. For service storage of sodium cyanide (cylinders and boxes), OXIQUIM has evidence of procedures for these operations. It was evident he was about a maintenance plan that contains the equipment for handling cyanide, which states: manufacturer, make, model and serial numbers and kinds of maintenance that must be maintain in accordance with the guidelines of manufacturer. Prior to their loading and use trucks are inspected by staff OXIQUIM to demonstrate any deviation that jeopardize the operation, based inspection in the format "Checklist Previous -Trip" if find any deviation is made the communication with the company carries for prior to the start of the operation solution. After the load is, fixed OXIQUIM makes a record of the weights and measures to record the weight of the load and verify that this does not exceed the maximum set of 20 TM as established in Peruvian Law by type of vehicle configuration. In addition, there are in all the routes used, controls weight and size of the Ministry of Transport and Communications (MTC) of Peru. Before giving the output of unit personnel OXIQUIM check that the carrier has the following duly completed documents. In addition, OXIQUIM staff inspects equipment of transport and equipment of load, considering the following points: Suitable for a transporter tonnage, lower antiquity to 5 years. Exterior and interior of the unit in good condition (no damage), forklift mast in good condition (no cracks or breaks), cleaning the unit as mirrors in good condition and complete, safety belts and operating clean, no signs of leaking oil, coolant or fuel, parking brake operative, operative wheels, alarm, back in good state. There are documented procedures that set the conditions in place to prevent overloading of the transport vehicle used for cyanide management; these include issues of safety and environment. The operation of loading and unloading of sodium cyanide is carry out in the switchyard outside the store, in front of the storage area Sodium Cyanide. During loading and unloading, has surveillance by a Warehouse Supervisor UNITRADE and Safety Inspector OXIQUIM. FEBRUARY 2014| OXIQUIM 11 Lead Auditor Signature 1.4 TRANSPORT PRACTICE 1.4 DEVELOP AND IMPLEMENT A SAFETY PROGRAM FOR TRANSPORT OF CYANIDE. X in full compliance with The operation is in substantial compliance with Transport Practice 1.4 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.4 requiring an operation Develop and implement a safety program for transport of cyanide. OXIQUIM established a transportation method avoiding disturbances during motion describing the administrative, operational and safety measures for the smooth operation of the transport of sodium cyanide. For the transport of sodium cyanide, OXIQUIM requests that the carrier count with a control room, with the GPS system continuously provide the positioning of each of the vehicles at all times. Before the trip, OXIQUIM verifies that the three visible sides of the vehicles are equip with UN Number, NFPA diamond and diamond DOT. Peruvian law fulfilled Supreme Decree 021-2008-MTC Regulation for the transport of hazardous materials / Waste. OXIQUIM check out by prior agreement of inspection units by OXIQUIM Staff to ensure that vehicles and escort vehicles are in good condition. OXIQUIM audited annually and unexpectedly the maintenance plan of the transport companies and the maintenance records of the units are revised, OXIQUIM has a prevent maintenance plan of the unit and was review maintenance records and practice was confirmed during the observation and was evident in the interview with OXIQUIM Safety Supervisor, and Drivers. OXIQUIM states that Drivers Transportation Companies should rest at least 8 hours before a trip and do not drive more than 12 hours a day and daylight driving only during the day. It is noteworthy that the Peruvian rules provide the same hours for the transport of hazardous materials "DS 021-2008-MTC Regulation of Transport Management Act “. OXIQUIM places the burden of cyanide must travel in containers of 10, 20 feet or 40 feet, developing mechanisms to prevent movement. OXIQUIM set your procedure; OXIQUIM supervisor in the warehouse must verify that the load must be properly secured in the container, during the visit by staff indicated that if necessary elements are used to secure the load so that the load does not move inside the container. FEBRUARY 2014| OXIQUIM 12 Lead Auditor Signature OXIQUIM states that the trip will take place in the way of convoy; the Convoy Leader is responsible for the assessment of weather conditions and is empowered to suspend the transport convoy. At the end of the trip, the leader of the operation and drivers must submit a report detailing the same route incidents, advance information, and find relevant and sensitive areas to ensure the safety and security information on future trips. OXIQUIM has a Policy of ZERO consumption of alcohol and drugs or any other substance that may impair or reduce the function of the transport driver. Prior to the commencement of activities necessary to perform a test alcohol test and periodically discard evidence of drug use, the violation of this policy has resulted in the separation of the worker from the Organization. Plans and procedures for compliance with the Code are review annually and annual follow-up audits will be develop to verify compliance with standards OXIQUIM. OXIQUIM establishes guidelines to ensure that their subcontractors comply with items 1, 2 and 3 of this must be respected according to the Transport Practice 1.4 It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA LOGISTICS and EDEWIT. Site: www.cyanidecode.org 1.5 TRANSPORT PRACTICE 1.5: FOLLOW INTERNATIONAL STANDARDS FOR TRANSPORTATION OF CYANIDE BY SEA AND AIR. X in full compliance with The operation is in substantial compliance with Transport Practice 1.5 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in NOT APPLICABLE whit Standard of Practice 1.5 requiring an operation Follow international standards for transportation of cyanide by sea and air. All receiving containers locked and transported by sea of according DG Code and IMO. OXIQUIM not transported by sea transport and air transport within the territory of Peru. FEBRUARY 2014| OXIQUIM 13 Lead Auditor Signature 1.6 TRANSPORT PRACTICE 1.6: TRACK CYANIDE SHIPMENTS TO PREVENT LOSSES DURING TRANSPORT. X in full compliance with The operation is in substantial compliance with Transport Practice 1.6 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.6 requiring an operation Track cyanide shipments to prevent losses during transport. OXIQUIM states that contract carriers must use a GPS system. They must also have a telephone service, radio and cellular pathway that ensures full coverage during movement and be fully connected to the control room where his base and OXIQUIM. In addition to providing, a system that continuously indicates the position of each vehicle at all times. OXIQUIM inspects the telephone lines are in operation prior to departure; further checks done to verify the operation of mobile equipment, GPS and radio by List PreTrip Inspection Authority. OXIQUIM has identified areas without cell coverage and radio, for it asks OXIQUIM contract carriers using satellite equipment. OXIQUIM verifies that the GPS system have transport companies that hire has location updates in real time also continually sought (periods not to exceed one hour) the location of the transport units. Before each trip OXIQUIM check the bill of lading and waybill, transported amounts of cyanide, Data Sheet Material Safety also this documentation must be available throughout the trip as OXIQUIM guidelines, this same data is review by Customer (final destination). Note that this information must be show to the inspectors if MTC is request otherwise the carrier be fine. OXIQUIM is secure before each trip that the sender reference guide to indicate the product name, number of the United Nations (UN), and weight of packages transported cargo quantity, and likewise that product safety considerations indicated. Upon delivery of the send, reference guide supplied Data Sheet Material Safety to the carrier. The lack of guidance sender reference and Data Sheet Material Safety during transport is fine by the confiscation of the cargo by the Peruvian government that makes mandatory controls on all tolls departure city Lima. It is worth mentioning that the sender reference guide should be preserve and stored by the carrier for not less than five (05) years’ time. OXIQUIM establishes guidelines to ensure that their subcontractors comply with the elements 1 to 6 of this, should be respected according to the Transport Practice 1.4 FEBRUARY 2014| OXIQUIM 14 Lead Auditor Signature It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA LOGISTICS and EDEWIT. Site: www.cyanidecode.org FEBRUARY 2014| OXIQUIM 15 Lead Auditor Signature 2 INTERIM STORAGE Design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent releases and exposures. 2.1 TRANSPORT PRACTICE 2.1 STORE CYANIDE IN A MANNER THAT MINIMIZES THE POTENTIAL FOR ACCIDENTAL RELEASES. X in full compliance with The operation is in substantial compliance with Transport Practice 2.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is NOT APPLICABLE whit Standard of Practice 2.1 requiring an operation Store cyanide in a manner that minimizes the potential for accidental releases. OXIQUIM within the supply chain hires UNITRADE as a distribution warehouse. FEBRUARY 2014| OXIQUIM 16 Lead Auditor Signature 3 EMERGENCY RESPONSE: Protect communities and the environment through the development of emergency response strategies and capabilities. 3.1 TRANSPORT PRACTICE 3.1: PREPARE DETAILED EMERGENCY RESPONSE PLANS FOR POTENTIAL CYANIDE RELEASES. X in full compliance with The operation is in substantial compliance with Transport Practice 3.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: OXIQUIM has an Emergency Response Plan, which is suitable for the selected transport route takes into account the chemical cyanide fitness and clearly points out the use of trucks to transport sodium cyanide considering the characteristics of this equipment and the structural conditions of the road where the transport of sodium cyanide is perform are evaluated. Information on road conditions are define in the Roadmap document. The Emergency Plan describes the response actions for emergencies previews. These were verify during the audit. It also establishes the logical line of actions that must take the leader and convoy drivers when irregularities arise during transport of sodium cyanide, including civil commotion, adverse conditions, bad weather, traffic congestion and unplanned stops. OXIQUIM establishes two levels of emergency response: The objective is to measure the efficiency of the response procedure to ensure that those involved act in case of an emergency, following from the Emergency Plan. The Head of Operations OXIQUIM takes into account the rapid preliminary compilation of the situation, gathering the basic facts as known at the time the who, what, where, when, how and why of the situation, contact the person responsible and retransmit information obtained continuously communicates with the Convoy Leader and will handle the requirement authorities. It also sets the limit of 20 tons between Level 1, Level 2 is, of course, arbitrary, and circumstances will decide when Level 2 is required. Within each level, there may be interaction between teams own and / or third parties and governmental response, both in regards to resource control and indicating in Contingency Plan that interaction. FEBRUARY 2014| OXIQUIM 17 Lead Auditor Signature It was evident that hires OXIQUIM Transport Companies certified by the ICMI like CITSSA LOGISTICS and EDEWIT. Site: www.cyanidecode.org 3.2 TRANSPORT PRACTICE 3.2: DESIGNATE APPROPRIATE RESPONSE PERSONNEL AND COMMIT NECESSARY RESOURCES FOR EMERGENCY RESPONSE. X in full compliance with The operation is in substantial compliance with Transport Practice 3.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: OXIQUIM, evidenced during the audit, which asks companies transport drivers and supervisors receive training in emergency response on safe cyanide management (spill and intoxication), and other courses must be trained in handling the defense, firefighting, first aid, hazardous materials level I and Level 2. knowledge in these areas further issuance of licenses by the transport companies is evidenced by staff OXIQUIM after interviews with the drivers where asks questions of the above issues and thus verify understanding of them, this was evident after reviewing records Checklist PreTrip. OXIQUIM asks carriers workouts are renew annually complying with the training plan; this is evidence by reviewing training plans 2014 verifying compliance with specific skills. External companies provide training. OXIQUIM establishes specific responsibilities in an emergency, differentiating responsibility OXIQUIM and his team, the company transportation and emergency response companies. Drivers with Enforcement Supervisors are responding in an emergency they pass medical tests to check physically for these activities and have receive the training necessary for efficient emergency response conditions. Each truck must have require amount of Emergency Response Teams and the security convoy also must have a Response Kit spills and poisoning (antidote kit) and Personal Protective Equipment to be verify before the trip, and verification before the start of travel and and periodic emergency response training. Check this practice was evident after reviewing the records of the Checklist Pre-Trip. OXIQUIM verifies that the carrier has the necessary equipment for emergency response in case of a larger and second activation OXIQUIM spill response activates the second answer. Inspection records of the response teams prior to each trip FEBRUARY 2014| OXIQUIM 18 Lead Auditor Signature through the emergency Checklist before Trip were check. The presence of these teams in the convoy was verify. The Emergency Plan indicates staff functions in an emergency, also the emergency equipment to be use in both the first and second response. The Emergency Plan describes specific emergency response roles and responsibilities of staff. The verification units is perform prior to each trip, for which the use of Pre-Checklist Travel format required. OXIQUIM trains staff and staff of transport company. The transport vehicle operators receive initial and periodic refresher training in emergency cyanide (Spill and poisoning) annually and emergency response procedures including implementation of the Emergency Responce Plan. Additionally organizes lectures before the trip indicating safety procedures and a summary of actions in an emergency. Delivering drivers summary information emergency response plan. During the audit process were interviewed to transport personnel and reported having received training. It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA LOGISTICS and EDEWIT. Site: www.cyanidecode.org. 3.3 TRANSPORT PRACTICE 3.3: DEVELOP PROCEDURES FOR INTERNAL AND EXTERNAL EMERGENCY NOTIFICATION AND REPORTING. X in full compliance with The operation is in substantial compliance with Transport Practice 3.3 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 3.2 requiring an operation develop procedures for internal and external emergency notification and reporting. It was evident that the contact information in case of emergency is update in case of emergencies and update the Emergency Plan in this case warrants. The Emergency Plan indicates the current list of contact, which is review, and updated through calls in each revision of Emergency Planning. By performing 02 calls to the numbers given in the contact list updating is evidenced contact numbers in case of emergency. The Emergency Plan includes an internal and external schema that specifies the call flow by the security personnel responsible for emergency, receptors, regulators, providers FEBRUARY 2014| OXIQUIM 19 Lead Auditor Signature outside responders, medical, fire, and communities that may be affect by an emergency. In OXIQUIM, Emergency Plan establishes procedures and formats for security and control of accidents and waste disposal resulting from these. Format of information for assessing the magnitude of the emergency occurred during the transport of materials and / or hazardous waste by road or rail accident or incident during transport. Reporting and Investigating Incidents / Accidents • Procedures for cleaning and decontamination major accident cyanide • Procedure for disposal of Sodium Cyanide • Security Primer for spills of solid sodium cyanide It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA LOGISTICS and EDEWIT. Site: www.cyanidecode.org 3.4 TRANSPORT PRACTICE 3.4: DEVELOP PROCEDURES FOR REMEDIATION OF RELEASES THAT RECOGNIZE THE ADDITIONAL HAZARDS OF CYANIDE TREATMENT CHEMICALS. X in full compliance with The operation is in substantial compliance with Transport Practice 3.4 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 3.4 requiring an operation develop procedures for remediation of releases that recognize the additional hazards of cyanide treatment chemicals. The Emergency Plan describing how the recovery will take or neutralize the solid, the decontamination of soils or other contaminate media and how manage these wastes. The Emergency Plan prohibits the use of chemicals such as sodium hypochlorite, ferrous sulfate and hydrogen peroxide to treat cyanide that has been release to surface waters. Evidences were available that OXIQUIM has develop procedures for remediation of releases that recognize the additional hazards of cyanide treatment chemicals. FEBRUARY 2014| OXIQUIM 20 Lead Auditor Signature 3.5 TRANSPORT PRACTICE 3.5: PERIODICALLY EVALUATE RESPONSE PROCEDURES AND CAPABILITIES AND REVISE THEM AS NEEDED. X in full compliance with The operation is in substantial compliance with Transport Practice 3.5 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 3.5 requiring an operation periodically evaluate response procedures and capabilities and revise them as needed. The Plan needs to be update at every opportunity there are changes in form and content, in terms of procedures, people, phone numbers, equipment, methods, or any other consideration to allow us to more effectively and efficiently. It should also be amended following comments during drills, emergencies, request any interested parties or at least ONE (01) once a year, I agree to the pages of signatures, the Plan was submit in November 2013. The site has an annual program of emergency drills including cyanide spill. Were carry out ONE (01) years in January 2014 and consisted of cyanide spill. The objective is to measure the efficiency of the response procedure to ensure that those involved act in case of an emergency, following from the Emergency Plan. The Head of Operations OXIQUIM takes into account the rapid preliminary compilation of the situation, gathering the basic facts as known at the time the who, what, where, when, how and why of the situation, contact the person responsible and retransmit information obtained continuously communicates with the Convoy Leader and will handle the requirement authorities. FEBRUARY 2014| OXIQUIM 21 Lead Auditor Signature FEBRUARY 2014| OXIQUIM 22 Lead Auditor Signature INTERNATIONAL CYANIDE MANAGEMENT CODE OXIQUIM PERU S.A.C., BASE PRODUCTION, CALLAO, PERU SUMMARY AUDIT REPORT FEBRUARY 2014 FEBRUARY 2014| OXIQUIM 1 Lead Auditor Signature INTERNATIONAL CYANIDE MANAGEMENT INSTITUTE Cyanide Production Operations Summary Audit Report For The International Cyanide Management Code and OXIQUIM PERU S.A.C. – Callao – Callao – Peru Verification Protocol www.cyanidecode.org February 2014 LIMA, PERU RIO DE JANEIRO, BRASIL FEBRUARY 2014| OXIQUIM 2 Lead Auditor Signature TABLE OF CONTENTS INTRODUCTION ..................................................................................................................................... 4 1 OPERATIONS .................................................................................................................................. 7 1.1 1.2 1.3 2 WORKER SAFETY ......................................................................................................................... 11 2.1 2.2 3 PRODUCTION PRACTICE 3.1 ........................................................................................................ 14 TRAINING ...................................................................................................................................... 15 4.1 4.2 5 PRODUCTION PRACTICE 2.1 ........................................................................................................ 11 PRODUCTION PRACTICE 2.2 ........................................................................................................ 12 MONITORING ............................................................................................................................... 14 3.1 4 PRODUCTION PRACTICE 1.1 .......................................................................................................... 7 PRODUCTION PRACTICE 1.2 .......................................................................................................... 8 PRODUCTION PRACTICE 1.3 ........................................................................................................ 10 PRODUCTION PRACTICE 4.1 ........................................................................................................ 15 PRODUCTION PRACTICE 4.2 ........................................................................................................ 16 EMERGENCY RESPONSE ........................................................................................................... 17 5.1 5.2 5.3 5.4 5.5 5.6 PRODUCTION PRACTICE 5.1 ........................................................................................................ 17 PRODUCTION PRACTICE 5.2 ........................................................................................................ 18 PRODUCTION PRACTICE 5.3 ........................................................................................................ 18 PRODUCTION PRACTICE 5.4 ........................................................................................................ 19 PRODUCTION PRACTICE 5.5 ........................................................................................................ 20 PRODUCTION PRACTICE 5.6 ........................................................................................................ 20 FEBRUARY 2014| OXIQUIM 3 Lead Auditor Signature INTRODUCTION Information on the audited operation Name of Cyanide Transportation Facility: OXIQUIM PERU SAC Name of Facility Owner: OXIQUIM PERU SAC Name of Facility Operator: OXIQUIM PERU SAC Name of Responsible Manager: LESLIE LEMBCKE Address: Av. San Borja Norte 166 State/Province/Country: San Borja/Lima / Perú Telephone: +51 1 225-1346 Fax: (511) -------------- E-mail: leslie.lembcke@oxiquim.pe Aspects of the location and description of the operation: OXIQUIM the largest subsidiary of Sintex-is a closed corporation engaged in the manufacture of resins for the wood panel industry and industrial resins, distribution of chemical products for industry and mining, and warehousing services and cargo / unloading liquid bulk ships in its maritime terminals located in the bay of Quintero and Coronel. In addition, The Company specializes in the distribution of products for pulp mills, fish, paint, food, textile, leather, pharmaceutical, plastics, agriculture and mining, among others. OXIQUIM Peru S.A.C. consolidates and begins commercial operations in the city of Lima at the beginning of 2005. Since then, his work in the distribution and marketing of a wide range of chemicals focuses incursions and exceptional representation of foreign chemical companies. These activities are relate in a complementary and synergistic manner with the main office. OXIQUIM Peru SAC stored sodium cyanide in wooden presentation boxes for 1TM and 50 kg cylinders. • Box IBC (Intermediate Bulk Container). It is a removable wooden box, 1, 4 m3 containing a poly bag with attachable handles the electric hoist. Inside this bag is a polypropylene bag in direct contact with sodium cyanide briquettes. The IBC box has a capacity of up to 1 ton. • Cylinder Metal: A metal cylinder contains inside a polythene bag in direct contact with sodium cyanide briquettes. The cylinder has a capacity of 50 kg. Operation OXIQUIM Peru SAC includes controlling the Storage Distribution (Downloading cyanide packaging containers, packaging storage and loading cyanide cyanide to packaging containers made by your UNITRADE) and control Transportation management distribution (Warehouse UNITRADE, is the distribution warehouse Customer). These activities are performed for 09 years with ZERO (00) accidents. The store OXIQUIM Sodium Cyanide, is located at 8651 Av. Néstor Gambetta, Callao, owned by the company UNITRADE SA, in an area zoned for big industry "I-3". The surface water bodies closest to the land, are the Pacific Ocean, approximately 70 m to the west and the river Chillón 1.300 m north of the site. FEBRUARY 2014| OXIQUIM 4 Lead Auditor Signature SUMMARY AUDIT REPORT FOR CYANIDE TRANSPORTATION OPERATIONS Instructions 1. The basis for the finding and/or statement of deficiencies for each Transport Practice should be summarized in this Summary Audit Report. This should be done in a few sentences or a paragraph. 2. The name of the cyanide transportation operation, lead auditor signature and date of the audit must be inserted on the bottom of each page of this Summary Audit Report. 3. An operation undergoing a Code Verification Audit that is in substantial compliance must submit a Corrective Action Plan with the Summary Audit Report. 4. The Summary Audit Report and Corrective Action Plan, if appropriate, for a cyanide transportation operation undergoing a Code Verification Audit with all required signatures must be submitted in hard copy to: International Cyanide Management Institute (ICMI) 1400 I Street, NW, Suite 550 Washington, DC 20005, USA 5. The submittal must be accompanied by 1) a letter from the owner or authorized representative which grants the ICMI permission to post the Summary Audit Report and Corrective Action Plan, if necessary, on the Code Website, and 2) a completed Auditor Credentials Form. The lead auditor’s signature on the Auditor Credentials Form must be certified by notarization or equivalent. 6. Action will not be taken on certification based on the Summary Audit Report until the application form for a Code signatory and the required fees are received by ICMI from the applicable cyanide transportation company. 7. The description of the cyanide transport company should include sufficient information to describe the scope and complexity of its operation. FEBRUARY 2014| OXIQUIM 5 Lead Auditor Signature Auditor’s Finding This Operation is: X in full compliance The International Cyanide Management Code in substantial compliance not in compliance with the International Cyanide Management Code. No significant cyanide incidents or exposures and releases were note as occurring during the audit period. Audit Company: ISOSURE SAC | JMAQ Audit Team Leader: Julio C. M. Monteiro E-mail: jmaq@ig.com.br / auditoria@iso-sure.com Date(s) of Audit: December 2014 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 conduct 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. Name and Signatures of Other Auditors Name Position Signature Date Julio Monteiro Lead Auditor / Production Technical 20 December 2014 Carlo Vargas Auditing Assistance 20 December 2014 FEBRUARY 2014| OXIQUIM 6 Lead Auditor Signature Verification Protocol 1 OPERATIONS Design, construct and operate cyanide production facilities to prevent release of cyanide. 1.1 PRODUCTION PRACTICE 1.1 DESIGN AND CONSTRUCT CYANIDE PRODUCTION FACILITIES CONSISTENT WITH SOUND, ACCEPTED ENGINEERING PRACTICES AND QUALITY CONTROL/QUALITY ASSURANCE PROCEDURES. X in full compliance with The operation is in substantial compliance with Production Practice 1.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.1 requiring an operation design and construct cyanide production facilities consistent with sound, accepted engineering practices and quality control/quality assurance procedures. The construction of storage facilities UNITRADE, company hired by OXIQUIM for storage of sodium cyanide were approved by the District Municipality of Callao, Callao, Peru, and subjected to quality control of municipal inspectors and customers of OXIQUIM. The designs and drawings submitted were approve under the structural considerations of seismic, electrical, fire, health, in accordance with the Rules of the Peruvian Structural Standards risks, and these are sign by a professional engineer qualified referee, enabling to UNITRADE for the Storage of Cylinders and Boxes with cyanide. These records are available at UNITRADE and were review during the audit. The review of building stores UNITRADE is performed by a multidisciplinary group of professionals made up 01 Structural Engineer 01 Sanitary Engineer, 01, Electrical Engineer 01 and 01 Architect Engineer Safety and Health at Work, which are qualified referees. This is done every two years and is a requirement of the Municipality of Callao, Peru to get the "License to Operate" It was evident that the last review was conducted in the month of January 2012 concluding APTA facilities UNITRADE for storage cylinders and boxes cyanide. OXIQUIM not handle cyanide state also, OXIQUIM has implement a management plan cyanide PR 001 Loading, Unloading and storage of sodium cyanide. FEBRUARY 2014| OXIQUIM 7 Lead Auditor Signature Cyanide is stacked up four levels, previously evaluate the strength of the case and in the case of cylinders are stacked up to two levels in the same pallet, and the blocks are stacked up to three levels. This will be monitors by Supervisor OXIQUIM and should storage separate from acids, weak alkaline, fuel, water / liquids, food (consume animals or human) Table 1: Companies from which the cyanide stored by OXIQUIM in UNITRADE Producers Anhui Anqing Shuguang Chemical TaeKwang Industrial Corporate Name Signatory Date Certification Date Anhui Anqing Shuguang Chemical Co., Ltd July 16, 2008 September 12, 2014 TaeKwang Industrial Co., Ltd June 22, 2006 May 12, 2013 There are quality control and quality assurance documentation. The warehouse built with concrete floor, brick walls and roof of calamine has a chute end to end to prevent water ingress as secondary containment. It also has natural ventilation, which consists of windows covered with microfiber, which allows air circulation and prevents the rain to pass if this was give. The failure or power outage does not affect the operation of OXIQUIM / UNITRADE nor cause a leak or spill. Warning system for reporting emergency brigade staff and hazardous materials to meet any spills promptly was evident. The boxes and cylinders of cyanide are stored on a pallet surface, which is on a concrete floor. OXIQUIM / UNITRADE not develop activities filling tanks, not involve the use of pipes and tanks for storage of cyanide or not employ the use of pipes for the storage solution cyanide. The failure or power outage does not affect the operation of OXIQUIM / UNITRADE nor cause a leak or spill. 1.2 PRODUCTION PRACTICE 1.2 DEVELOP AND IMPLEMENT PLANS AND PROCEDURES TO OPERATE CYANIDE PRODUCTION FACILITIES IN A MANNER THAT PREVENTS ACCIDENTAL RELEASES. X in full compliance with The operation is in substantial compliance with Production Practice 1.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: FEBRUARY 2014| OXIQUIM 8 Lead Auditor Signature The operation is in FULL COMPLIANCE whit Standard of Practice 1.2 requiring an operation develop and implement plans and procedures to operate cyanide production facilities in a manner that prevents accidental releases. The standard practices necessary for the safe and environmentally responsible operation are verify and documented as described in AB 001, Loading & Unloading and Storage Sodium Cyanide. OXIQUIM is aware of the dangers and risks involved in the use of sodium cyanide during storage, therefore, has developed an emergency plan for cyanide management Emergency Plan - Sodium Cyanide Management. The Plan allows them to ensure the safety and health of its employees, customers, contractors, visitors and others; and to fulfill the commitment to prevent or minimize the risk to health in an appropriate, timely and coordinate emergencies response. Oxiquim has a procedure in place and implemented to identify when site operating practices have or will be changed from those on which the initial design and operating practices were predicated. Additional, OXIQUIM set to the Emergency Plan - Sodium Cyanide Management changes are made in the Plan, provided that no changes in the patterns or practices, or if the parties each (Peruvian State, Customers, Partners, Suppliers, Emergency Support Centers information) changes or modifications. UNITRADE implemented a program of preventive maintenance of equipment (Forklift), maintenance and repair, which is verify by OXIQUIM. Maintenance records of equipment used for loading / unloading and storage of cyanide were check. During the entry or exit from storage, the levels of hydrogen cyanide (HCN) are control with a calibrated instrument. OXIQUIM has TWO (02) monitoring equipment. The Emergency Plan - Sodium Cyanide Management establishes procedures to dispose of cyanide in contaminated soil. The storage facility OXIQUIM / UNITRADE is build for ventilation naturally has windows, which are cover with microfiber, which allows entry of air entering avoiding rain. The storage area OXIQUIM / UNITRADE has tin roof and brick walls, additionally has a system of gutters to catch rainwater and direct it to a sump, the windows are cover with microfiber for ventilation but prevent entry rainwater. It also has a secondary containment system that consists of a trough which avoids water ingress and this is located opposite the entrance doors of the store. OXIQUIM makes a Risk Assessment Matrix of loading, unloading and storage. Access to the Warehouse for OXIQUIM / UNITRADE is restricted, prohibited the public has a perimeter fence 6 feet tall and security based on two (02) security guards, also has a closed system of security cameras. The cyanide is packaged as required peruvian political jurisdiction. FEBRUARY 2014| OXIQUIM 9 Lead Auditor Signature 1.3 PRODUCTION PRACTICE 1.3 INSPECT CYANIDE PRODUCTION FACILITIES TO ENSURE THEIR INTEGRITY AND PREVENT ACCIDENTAL RELEASES. X in full compliance with The operation is in substantial compliance with Production Practice 1.3 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 1.3 requiring an operation inspect cyanide production facilities to ensure their integrity and prevent accidental releases. No tanks containing cyanide solutions in OXIQUIM facilities. No piping, pumps or valves handle cyanide solutions on site. The inspections of the storage area are performed continuously cyanide. Further inspection records showed, that identify the same incidents, required actions. FEBRUARY 2014| OXIQUIM 10 Lead Auditor Signature 2 WORKER SAFETY Protect workers’ health and safety from exposure to cyanide. 2.1 PRODUCTION PRACTICE 2.1 DEVELOP AND IMPLEMENT PROCEDURES TO PROTECT PLANT PERSONNEL FROM EXPOSURE TO CYANIDE. X in full compliance with The operation is in substantial compliance with Production Practice 2.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 2.1 requiring an operation develop and implement procedures to protect plant personnel from exposure to cyanide. OXIQUIM has developed the method of PR 001 Loading, Unloading and Storage of Sodium Cyanide. This procedure includes the practices required for receipt, storage and dispatch of cyanide, indicating the needs of personal protective equipment and training requirements. Relevant staff were interview during the audit and were well inform of the requirements of the procedures and practices, as do reportedly are in concordance with what is contained in the procedure. Since installation is just a storage facility, emergency operations are only included in the Emergency Plan - Cyanide Management. In addition, maintenance is relate only to forklifts, held outside the company premises by the supplier of the equipment. The site has a Risk Assessment Matrix being responsible Head of Mining Operations to review and update it whenever significant changes including the cyanide management practices are perform Workers participate in relevant meetings and review of procedures safety and health issues at work company by the supplier of the equipment. OXIQUIM has two (02) controlling detectors cyanide gas concentrations of cyanide (HCN), while unloading containers of cyanide; detectors are calibrate to alarm at 4.7 ppm. The detectors are calibrate and a calibration certificate is issue by the manufacturer. FEBRUARY 2014| OXIQUIM 11 Lead Auditor Signature Reportedly, they have not identified areas or activities with concentrations of cyanide gas (HCN). Despite this, class A Personal Protective Equipment (encapsulated suit) is required in the installation and use of cyanide when a container is damage and repairs made to it. To the "buddy system" is set for establishing activities that cyanide must have minimum two persons and 1 extra person for supervision. Radios and telephones used to communicate between the relevant personnel related to the operations of cyanide. Forklift operators have radios with them at all times. Pre-employment medical examinations are required before hiring new staff, periodically while working on OXIQUIM / UNITRADE, and out OXIQUIM / UNITRADE. Specific requirements are define for different trades and positions. Relevant documentation was review during the audit in connection with this. Disposable Suits level C are use as part of the Personal Protective Equipment required tasks in loading and unloading of cyanide. There are warning signs posted on the cyanide storage area, advising is that cyanide is present and, if necessary, the appropriate personal protective equipment should be used. In addition, smoking is prohibited, dining, and open flames in areas where there is the possibility of contamination by cyanide. 2.2 PRODUCTION PRACTICE 2.2 DEVELOP AND IMPLEMENT PLANS AND PROCEDURES FOR RAPID AND EFFECTIVE RESPONSE TO CYANIDE EXPOSURE. X in full compliance with The operation is in substantial compliance with Production Practice 2.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 2.2 requiring an operation develop and implement plans and procedures for rapid and effective response to cyanide exposure. OXIQUIM has implemented a couple to care and accident investigation methodology, which aims to ensure that all accidents and near misses are report and investigated immediately in order to make the respective corrections. This procedure is the responsibility of the Head of Mining Operations. The procedure is divide into the FEBRUARY 2014| OXIQUIM 12 Lead Auditor Signature accident / incident care, Accident Investigation / Treatment Failure and the accident / incident. As part of this research, this method indicates that the investigation of the incident / accident must be support by a report. OXIQUIM reports no accidents occurred with cyanide or whatever is involved, information validated by interviews with company personnel operative. OXIQUIM has Emergency Plan, which deals with spills, fires and poisoning due to exposure to cyanide. This plan has been included in the Annual Training Plan. OXIQUIM has portable wash stations eyes low-pressure dry chemical extinguishers 50Kg per house 50 meters. According to eyewash stations, interviewed staff are inspect daily and extinguishers are inspect once a month. The facility has water, oxygen tank, antidote and trained personnel to provide first aid (oxygen and amyl nitrite) to assist an employee exposed. Employees have the radio for internal communication and installation telephony features. OXIQUIM has launched an inspection checklist whenever operations are perform with cyanide (loading and unloading); including minimum amounts of first aid and emergency response teams. Checklists from January 2014 until the date of the audit were review; availability of equipment was confirm during the audit. The MSDS is in Spanish language and was available off the cyanide storage area. No tanks, pipes or containers. Allowed only by authorized personnel enter the area. Disposable Tyvek Suit (Level C) is required to enter the area. The facility does not have a doctor on site but has a health center 10 minutes away by car you are familiar with the symptoms of cyanide poisoning and first aid procedures. As oxygen tank mentioned above and antidote kit are also available on the site. The Emergency Plan includes a method for transporting workers exposed to the nearest medical facility. This procedure indicates in which case the exposed worker must be evacuate, and the name and address of the medical center; how the worker will be expose and the exposed worker is transported at all times. Written communications with external response were available for review (they were made in December 2013 and is held annually), including the health center. The communication indicates that the health center will provide medical care for exposed personnel. OXIQUIM conducted one emergency drill regarding cyanide spill from ruptured box. OXIQUIM has an accident investigation methodology. As part of this research, the process of the investigation indicates that the incident must be support by a report. FEBRUARY 2014| OXIQUIM 13 Lead Auditor Signature 3 MONITORING Ensure that process environment. controls are protective of the 3.1 PRODUCTION PRACTICE 3.1 CONDUCT ENVIRONMENTAL MONITORING TO CONFIRM THAT PLANNED OR UNPLANNED RELEASES OF CYANIDE DO NOT RESULT IN ADVERSE IMPACTS. X in full compliance with The operation is in substantial compliance with Production Practice 3.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 3.1 requiring an operation conduct environmental monitoring to confirm that planned or unplanned releases of cyanide do not result in adverse impacts. OXIQUIM makes the finished product storage UNITRADE, cyanide is not remove from its package; operations do not generate air emissions or wastewater containing cyanide in normal conditions. The waste generated by an emergency would be handle as hazardous waste. This section does not apply to facilities. OXIQUIM makes no discharges to surface waters, stored OXIQUIM presentation end briquettes packed in boxes and cylinders product. The waste generated by an emergency would be handle as hazardous waste. OXIQUIM not perform any type of discharge, terminated OXIQUIM stores briquettes packed in presentation boxes and cylinders product. The waste generated by an emergency would be handle as hazardous waste. OXIQUIM not perform any type of indirect discharge to surface water, stored OXIQUIM finished briquettes packed in presentation boxes and cylinders product. FEBRUARY 2014| OXIQUIM 14 Lead Auditor Signature 4 TRAINING Train workers and emergency response personnel to manage cyanide in a safe and environmentally protective manner. 4.1 PRODUCTION PRACTICE 4.1 TRAIN EMPLOYEES TO OPERATE THE PLANT IN A MANNER THAT MINIMIZES THE POTENTIAL FOR CYANIDE EXPOSURES AND RELEASES. X in full compliance with The operation is in substantial compliance with Production Practice 4.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 4.1 requiring an operation train employees to operate the plant in a manner that minimizes the potential for cyanide exposures and releases. OXIQUIM has an annual training program in which the hazard identification and training is given on risk analysis (IPER for its acronym in Spanish) to all operators of cyanide. This training is deliver by the Head of Mining Operations OXIQUIM once a year and lasts one hour. Training records were review during the audit. The Head of Mining Operations OXIQUIM and Safety Officer UNITRADE maintain all training records recorded and archived. All training sessions included in the annual training program has been designed as a result of hazard identification and risk assessment to address the risks associated with the activities of each job in the warehouse. OXIQUIM provides training programs for workers in annual form, the training program of 2014 on the entire course "Personal Protective Equipment" included was evident. OXIQUIM names a person or entity responsible for each training session, all of which are OXIQUIM qualified staff and external companies. OXIQUIM has a procedure for evaluating potential suppliers in terms of their suitability to work with OXIQUIM. According to PR 001 Loading, Unloading and Storage of Sodium Cyanide Sodium "all personnel operating cyanide must have prior training. When interviewed stated that an employee had been trained before the start of its activities in the company. FEBRUARY 2014| OXIQUIM 15 Lead Auditor Signature The efficiency of formation of cyanide is test during exposure to cyanide or cyanide spill drills according to OXIQUIM training program. A separate report is prepared in the wake of each year based on the results of the need for training is present and communicate. In addition, the courses taught by qualified third minimum passing grade of 13 otherwise they must retake the course. 4.2 PRODUCTION PRACTICE 4.2 TRAIN EMPLOYEES TO RESPOND TO CYANIDE EXPOSURES AND RELEASES. X in full compliance with The operation is in substantial compliance with Production Practice 4.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 4.2 requiring an operation train employees to respond to cyanide exposures and releases. OXIQUIM has the Emergency Plan - Sodium Cyanide Management, in which all employees are training in the different scenarios that could result in a release cyanide as emergently. This is impart by the Chief Mining-OXIQUIM training once a year. Training Program of OXIQUIM Indicates that must perform TWO (02) exhaust drills of cyanide per year. Simulations performed are evaluate in terms of effectiveness, to determine the level of knowledge, skills, and identifying weaknesses of staff and the organization. This assessment was evident in the reports of the drills conducted in 2013. Training records were review to confirm the execution of the training program described above. These records include the names and signatures of the worker as worker and trainer, date of training and the topics covered. Three Employees were interview and responded correctly to all questions regarding cyanide management in your work area. FEBRUARY 2014| OXIQUIM 16 Lead Auditor Signature 5 EMERGENCY RESPONSE Protect communities and the environment through the development of emergency response strategies and capabilities. 5.1 PRODUCTION PRACTICE 5.1 PREPARE DETAILED EMERGENCY RESPONSE PLANS FOR POTENTIAL CYANIDE RELEASES. X in full compliance with The operation is in substantial compliance with Production Practice 5.1 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.1 requiring an operation prepare detailed emergency response plans for potential cyanide releases. OXIQUIM developed the Emergency Plan - Sodium Cyanide Management (hereinafter referred to as the Plan). The Plan is a document that covers all operations during the operations in the warehouse. A section that describes the characteristics of sodium cyanide, emergency organization, communication protocol, and emergency evaluation levels are included. The scenarios are relate to releases of wooden boxes and action plan includes specific response to these scenarios. The Plan does not include instructions to evacuate communities as possible scenarios have consequences beyond the limits of the facilities OXIQUIM. In addition, OXIQUIM only manages sodium cyanide in solid state (briquettes) no residential areas adjacent to the facility. In addition, the Plan includes specific instructions and detailed response to the identified scenarios. The Plan comprises a method for the treatment of poisoning of people spilled cyanide reaction portion includes instructions for the use of cyanide antidotes and first aid procedures. The medical staff of the health center is familiar with these procedures. In The Plan actions in the case a spill occurs has specified actions to control of releases at their source. OXIQUIM Plan will be review after an emergency. This would help prevent future releases. FEBRUARY 2014| OXIQUIM 17 Lead Auditor Signature 5.2 PRODUCTION PRACTICE 5.2 INVOLVE SITE PERSONNEL AND STAKEHOLDERS IN THE PLANNING PROCESS. X in full compliance with The operation is in substantial compliance with Production Practice 5.2 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.2 requiring an operation involve site personnel and stakeholders in the planning process. The Chief Mining OXIQUIM developed the plan. The nearest residential area is located more than 1 km of the facility. According to the emergency response procedure at worst an area of 400 m should be evacuate; not covering the residential area. However, OXIQUIM government informed the district about its operations and that require their support OXIQUIM evacuate in an emergency. OXIQUIM has contacted the local police, local firefighters, and ocal hospital, and informed them that are consider as supporting facilities for emergency cyanide. The Plan includes a communications protocol in writing stating the emergency communication should be with all Stakeholders, including; Employees, Customers, Regulatory Agencies and other institutions. 5.3 PRODUCTION PRACTICE 5.3 DESIGNATE APPROPRIATE PERSONNEL AND COMMIT NECESSARY EQUIPMENT AND RESOURCES FOR EMERGENCY RESPONSE. X in full compliance with The operation is in substantial compliance with Production Practice 5.3 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.3 requiring an operation designate appropriate personnel and commit necessary equipment and resources for emergency response. FEBRUARY 2014| OXIQUIM 18 Lead Auditor Signature The Plan includes the name of the individual members of the emergency committee and outlines their roles and responsibilities. In general, high - more current manager in place that authority is grant to provide all necessary resources. The Plan also shows the contact number of the coordinators of alternative emergency response. The Plan determines that workers in the operation of cyanide will be part of the emergency team. Training in emergency response is generally to all staff and this training is included in the annual training program the same annual program. The Plan shows the contact information of those responsible (Crisis Committee). This plan states that these members have been give phones must respond at all times (24 hours). Plan the roles and responsibilities of the emergency committee for each emergency stage (before, during and after) are list. Plan includes a list of emergency response kit and personal protective equipment. The site has implemented a checklist inspection prior to any operation with cyanide and equipment availability was confirm during the audit. The Plan also includes the role of outside responders. The plan shows the contact details of all external entities involved. It further states that these entities are inform on an annual basis on the contingency plan and operational risks. 5.4 PRODUCTION PRACTICE 5.4 DEVELOP PROCEDURES FOR INTERNAL AND EXTERNAL EMERGENCY NOTIFICATION AND REPORTING. X in full compliance with The operation is in substantial compliance with Production Practice 5.4 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.4 requiring an operation develop procedures for internal and external emergency notification and reporting. The plan includes a communication protocol that includes internal communication functions, as well as notification to the authorities and external response personnel. FEBRUARY 2014| OXIQUIM 19 Lead Auditor Signature The Plan includes a directory of internal and external contacts. It also displays the contact information of the entire team of internal and external response to emergencies; members of that team have telephones and are available 24 hours a day that was check after calls to these numbers during the visit. Plan evacuation of communities deemed necessary. Click for communication with Authorities and External Response Personnel. 5.5 PRODUCTION PRACTICE 5.5 INCORPORATE INTO RESPONSE PLANS AND REMEDIATION MEASURES MONITORING ELEMENTS THAT ACCOUNT FOR THE ADDITIONAL HAZARDS OF USING CYANIDE TREATMENT CHEMICALS. X in full compliance with The operation is in substantial compliance with Production Practice 5.5 not in compliance with Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.5 requiring an operation incorporate into response plans and remediation measures monitoring elements that account for the additional hazards of using cyanide treatment chemicals. The plan describes the methodology to decontaminate, remediate soil or other contaminated materials and dispose of all spill cleanup debris and bodies of water test for the presence of cyanide. In the Plan prohibit the use of chemicals such as sodium hypochlorite, ferrous sulfate and hydrogen peroxide to treat cyanide that has been released into surface water. Based on the Risk Assessment Matrix, there is potential to affect water bodies. None of specific scenarios rather think that a spill would reach the floor or water. The monitoring is limited to the air and is carried out with detector gas cyanide (HCN) portable. 5.6 PRODUCTION PRACTICE 5.6 PERIODICALLY EVALUATE RESPONSE PROCEDURES AND CAPABILITIES AND REVISE THEM AS NEEDED. X in full compliance with The operation is in substantial compliance with Production Practice 5.6 not in compliance with FEBRUARY 2014| OXIQUIM 20 Lead Auditor Signature Summarize the basis for this Finding/Deficiencies Identified: The operation is in FULL COMPLIANCE whit Standard of Practice 5.6 requiring an operation periodically evaluate response procedures and capabilities and revise them as needed. In the plan provides that the Chief Mining - OXIQUIM should review the Plan after each mock emergency after emergency. According to the pages of signatures, the plan was submitted in December 2013 and was under review at the time of the audit. The site has an Annual Program of Emergency Drills including cyanide spill. Were carry out one (01) year in November 2013 and consisted of cyanide spill. FEBRUARY 2014| OXIQUIM 21 Lead Auditor Signature FEBRUARY 2014| OXIQUIM 22 Lead Auditor Signature
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