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
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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
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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
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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.
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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.
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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
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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.
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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.
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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).
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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
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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.
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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.
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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.
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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
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It was evident that OXIQUIM Transport hires certified by the ICMI like CITSSA
LOGISTICS and EDEWIT.
Site: www.cyanidecode.org
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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.
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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.
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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
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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
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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.
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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.
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INTERNATIONAL CYANIDE MANAGEMENT CODE
OXIQUIM PERU S.A.C., BASE PRODUCTION, CALLAO,
PERU
SUMMARY AUDIT REPORT
FEBRUARY 2014
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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
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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
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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.
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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.
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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
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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.
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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:
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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Lead Auditor Signature
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Lead Auditor Signature