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DRAFT Environmental Management Programme for the South African National Blood Service (SANBS) Pinetown Campus in KwaZulu-Natal, South Africa This Environmental Management Programme (EMP) is based on the EMP framework as detailed in Section 24N of the National Environmental Management Amendment Act (Act No. 62 of 2008), Regulation 34 of the EIA Regulations R.385 21 April 2006, and Regulation 33 of the EIA Regulations R.543 18 June 2010. Operational Activities as well as potential future Maintenance, Construction and / or Expansion Activities DEA Reference Number: 12/9/11/L825/4 For submission to: Department of Environmental Affairs Compiled for: South African National Blood Service (SANBS) Compiled by: EcoAfrica Environmental Consultants Gauteng (Pty) Ltd. www.ecoafrica.co.za March 2013

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DRAFT

Environmental Management

Programme for the South African National

Blood Service (SANBS) Pinetown Campus in

KwaZulu-Natal, South Africa This Environmental Management Programme (EMP) is based on the EMP framework as detailed in

Section 24N of the National Environmental Management Amendment Act (Act No. 62 of 2008),

Regulation 34 of the EIA Regulations R.385 21 April 2006, and Regulation 33 of the EIA Regulations

R.543 18 June 2010.

Operational Activities

as well as potential future Maintenance,

Construction and / or Expansion Activities

DEA Reference Number: 12/9/11/L825/4

For submission to:

Department of Environmental Affairs

Compiled for:

South African National Blood Service (SANBS)

Compiled by:

EcoAfrica Environmental Consultants Gauteng (Pty) Ltd.

www.ecoafrica.co.za

March 2013

EcoAfrica Environmental Consultants

Environmental Management Programme for the South African National Blood Service, Pinetown Campus, Kwazulu-Natal.

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Table of Contents

1. Introduction .............................................................................................................................................. 4

1.1 Purpose of the EMP and relevant activity components ..................................................................... 4

1.2 Adoption and Implementation of the EMP ........................................................................................ 5

1.3 Operational Activities within the SANBS Pinetown Campus .............................................................. 6

1.4 Relevant Standards ............................................................................................................................. 7

2. Operational Environmental Management ................................................................................................ 7

2.1 Security and Access Control ............................................................................................................... 7

2.2 Waste Management ........................................................................................................................... 8

2.2.1 Health Care Risk Waste ............................................................................................................... 8

2.2.2 Health Care General Waste......................................................................................................... 9

2.2.3 Waste Transfer Facilities ............................................................................................................. 9

2.2.4 Fill Platform Management ........................................................................................................ 10

2.2.5 Trade Effluent............................................................................................................................ 10

2.2.6 Vehicle Workshop Effluent........................................................................................................ 10

2.2.7 Waste Facility Effluent / Run-off ............................................................................................... 11

2.3 Transportation Safety ....................................................................................................................... 11

2.4 Dispatching of Products and Goods ................................................................................................. 11

2.5 Incident Management Procedures ................................................................................................... 11

3. Potential Future Maintenance Activities ................................................................................................ 13

4. Potential Future Construction and / or Expansion Activities ................................................................. 13

5. General Construction Control Guidelines ............................................................................................... 14

5.1 Environmental Control Officer ......................................................................................................... 14

5.2 Contractor’s Responsibility and the Polluter Pays Principle ............................................................ 14

5.3 Environmental Awareness Training for Site Personnel .................................................................... 14

5.4 Communication Procedures ............................................................................................................. 14

5.4.1 Site Instruction Book ................................................................................................................. 14

5.4.2 Environmental Control Monitoring Reports ............................................................................. 15

5.4.3 Environmental Method Statements ......................................................................................... 15

5.4.4 Environmental Auditing ............................................................................................................ 15

5.4.5 Record Keeping ......................................................................................................................... 16

5.4.6 DWA Notification ...................................................................................................................... 16

5.5 Environmental Management of Construction Activities .................................................................. 16

5.5.1 Contractor’s Camp .................................................................................................................... 16

5.5.2 Use of Local Labour ................................................................................................................... 16

5.5.3 Protection of Natural Environmental Features and Heritage Resources ................................. 17

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5.5.4 Demarcation of the Site ............................................................................................................ 17

5.5.5 Site Access ................................................................................................................................. 18

5.5.6 Establishment of Working and Storage Areas .......................................................................... 18

5.5.7 Establishment of Maintenance and Service Areas.................................................................... 18

5.5.8 Fuels and Flammable Materials ................................................................................................ 18

5.5.9 Appropriate Use of Machinery.................................................................................................. 19

5.5.10 Care of Existing Services.......................................................................................................... 19

5.5.11 Top Material and Stockpiling .................................................................................................. 19

5.5.12 Earthworks .............................................................................................................................. 19

5.5.13 Blasting / Drilling ..................................................................................................................... 19

5.5.14 Top Material and Stockpiling .................................................................................................. 20

5.5.15 Construction Materials............................................................................................................ 20

5.5.16 Cement Works......................................................................................................................... 20

5.5.17 Brick Works ............................................................................................................................. 21

5.5.18 Wood Works............................................................................................................................ 21

5.5.19 Plaster Works .......................................................................................................................... 21

5.5.20 Paint Works ............................................................................................................................. 21

5.5.21 Roof Insulation Material ......................................................................................................... 22

5.5.22 Discharge of Construction Effluent ......................................................................................... 22

5.5.23 Handling of Hazardous Construction Materials ...................................................................... 22

5.5.24 Integrated Waste Management and Pollution Control .......................................................... 22

5.5.25 Dust Control ............................................................................................................................ 23

5.5.26 Fire Prevention Measures ....................................................................................................... 23

5.5.27 Toilets ...................................................................................................................................... 24

5.5.28 Stabilisation and Rehabilitation of Construction Site ............................................................. 24

5.5.29 Site Clean Up ........................................................................................................................... 24

Appendix A: INF-SEP-012 Rev0 Waste Management Guidelines (HCRW and HCGW) ............................... 25

Appendix B: SOP-HSE-007 Rev0 Waste (HCRW & HCGW) and Environmental Management ................... 35

Appendix C: Classification, segregation, storage and disposal of wastes .................................................. 43

Appendix D: Recent Waste Disposal Certificates........................................................................................ 46

Appendix E: Valid Trade Effluent Permit .................................................................................................... 53

Appendix F: CP-TRA-002.0 Transportation Safety Procedures ................................................................... 55

Appendix G: SOP-TRA-001.0 Dispatching Products and Goods using a Courier Waybill ........................... 62

Appendix H:SOP-HSE-003 Safety, Health and Environment Incident Management .................................. 68

Appendix I: Environmental awareness do’s and don’ts summary sheets .................................................. 79

Appendix J: Environmental method statement template .......................................................................... 83

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1. Introduction

The South African National Blood Service (SANBS) provides an essential service within South

Africa and are rated among the best in the world in the provision of blood and blood products,

as well as in relation to research and training provided in their field. SANBS is regarded as a

major health service role player locally, nationally, in the SADC region as well as

internationally.

The mission of SANBS is to provide all patients with sufficient, safe, quality blood products and

medical services related to blood transfusion, in an equitable and cost effective manner.

1.1 Purpose of the EMP and relevant activity components

This Environmental Management Programme (EMP) document describes the management,

mitigation, protection and/or remedial measures that will be followed in order to address the

identified environmental impacts of the Operational Phase as well as potential future

Maintenance, Construction and / or Expansion of the current relevant activity components

that trigger listed activities in terms of the Waste Act, 2008, (hereafter referred to as the

“Development”) and to ensure that these impacts are minimised and/or prevented. With

reference to the related Basic Assessment EIA documentation, these applied-for activity

components consist of:

Hazardous Waste Transfer Facilities:

1a. An existing transfer facility, being a biohazardous waste transfer facility (existing max.

capacity approx. 130m3), which is used to temporarily store health care risk waste which

is then removed by independent service providers for disposal off-site. Recyclable

material as well as health care general waste is also temporarily stored in a separately

designated portion of this facility (please note that these recyclable and general waste

storage and transfer activities fall below the thresholds specified in terms of the Waste

Act, and thus do not require a Waste License). This facility is owned and operated by

SANBS. The following alterations to this facility are proposed:

• Expansion of the building by approximately 50m2

• Incorporating of the existing chemical waste transfer activities currently managed at

facility 1b. (described below) into facility 1a.

• The proposed new waste storage capacities at facility 1a. will be as follows:

- Biohazardous waste: ± 54m3

- Chemical waste: ± 34m3

- Recyclable material: ± 40m3

- General waste: ± 31m3

Accordingly, the operational waste license being applied for under facility 1a. pertains to

the current waste transfer activities 1a. and 1b (biohazardous waste transfer and

chemical waste transfer).

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1b. An existing transfer facility, being a chemical waste transfer facility (existing max capacity

approx. 68m3), which is used to temporarily store health care risk waste, which is then

removed by independent service providers for disposal off-site. This facility is owned and

operated by SANBS. It is proposed to transfer this facility’s function of chemical waste

transfer into facility 1a above, following which, the structure (1b) will be returned to its

original use as a general maintenance building. Accordingly, a waste license for facility 1b.

is not being applied for, as this waste stream is being applied for under waste facility 1a.

above.

1c. An existing transfer facility, being a biohazardous and chemical waste transfer facility

(existing max. capacity approx. 39.4m3), which is used to temporarily store health care

risk waste, which is then removed by independent service providers for disposal off-site.

This transfer facility is owned by SANBS and leased to the National Bioproducts Institute

(NBI) of South Africa for NBI operations. No changes to this facility are proposed. An

operational waste license is therefore being applied for, for the existing waste transfer

activities at facility 1c.

Inert Waste Disposal:

2. An existing ‘disposal’ facility, being the fill platform consisting of inert spoil material and

building rubble that has been historically disposed of to land as backfill. The fill platform

was initially commissioned in 1990. Additional material may be added during future

maintenance and / or expansion activities within the SANBS Pinetown campus. An

operational waste license is being applied for, for the disposal activities at facility 2.

This EMP furthermore contains detail regarding relevant operational activities and

environmental management system procedures that are implemented by SANBS within the

Pinetown Campus in KwaZulu-Natal, South Africa. The EMP also contains provisions and

guidelines for potential future maintenance activities, as well as regarding potential future

construction and / or expansion activities in terms of general construction control guidelines.

This EMP is a “living document” and will be updated and/or amended at any time should it

become clear that additional guidelines or requirements are necessary. All future maintenance

activities that become necessary within the Development, for instance in response to

weathering, flood damage, fire etc., must be conducted in accordance with the provisions of

this EMP. Any future construction / expansions to the Development and / or any of its facilities

may require Environmental Authorisation.

This EMP should form part of the relevant contract documentation related to

operation, maintenance, construction and / or expansion activities within the

Campus.

1.2 Adoption and Implementation of the EMP

The holder of the Environmental Authorisation for the Development is legally bound to

conduct the activity in line with the provisions contained within this EMP document.

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1.3 Operational Activities within the SANBS Pinetown Campus

The SANBS Pinetown Campus is wholly owned by SANBS, with most of the facilities being

operated by SANBS while several facilities are leased to the National Bioproducts Institute

(NBI), for their operations.

Operational activities within the SANBS Pinetown Campus include the storage and utilisation

of Medical Goods and Dangerous Goods, as well as the generation and temporary storage of

Health Care Risk Waste (HCRW) and Health Care General Waste (HCGW), including recyclables.

Such HCRW and HCGW is temporarily stored in several waste transfer facilities within the

Campus and removed for appropriate disposal by independent waste service providers. Trade

effluent is disposed of into the local municipal sewerage system. Vehicle workshop effluent is

disposed of through independent waste service providers.

Figure 1 below illustrates the goods and waste types that are typically relevant to the Campus.

Figure 1: Examples of typical goods and waste types present at the SANBS Pinetown Campus

and generated by the SANBS and NBI operations.

Medical Goods

Blood samples

Other medical

goods

Dangerous Goods

Gases

Flammable liquids

Flammable solids

Oxidising

substances

Toxic and infectious

substances

Corrosives

Health Care Risk Waste

Chemical waste

Sharps and softs

waste

Infectious waste

Anatomical waste

Pharmaceutical

waste

Electronic waste

Asbestos waste

Health Care General Waste

Office, kitchen and

canteen wastes

Compostable

garden waste

Recyclables (paper,

cardboard, plastics, oil, glass, metals,

wood)

Inert construction

waste

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1.4 Relevant Standards

The following standards have been taken into consideration by SANBS with regard to the

operations of the Pinetown Campus.

SANS 10248:1:2008 Management of healthcare waste from a healthcare facility

SANS 10248:2:2009 Management of healthcare risk waste for healthcare facilities and

healthcare providers in rural and remote settings

SANS 10248:3:2011 Management of healthcare risk waste from minor generators –

Registered healthcare professionals and non-healthcare professionals

SANS 10228 The identification and classification of Dangerous Substances and

Goods.

2. Operational Environmental Management

This section details the environmental management procedures that are to be followed

regarding operational activities within the SANBS Pinetown Campus.

2.1 Security and Access Control

Procedures for security and access control at the Campus include the use of guardhouse entry

control points, pre-authorised waste pickup schedules and staff member Access Control Cards.

The guardhouse entry control points are to facilitate access to authorised independent waste

service providers as well as visitors to the Campus. The following control procedures are

implemented at the guardhouses by appointed security personnel:

a. Independent waste service providers visit the Campuses according to a pre-authorised

waste pick-up schedule.

b. Independent waste service providers conducting a pickup of waste report to security and

liaise directly with the relevant on-site waste transfer facility or “transfer station”.

c. When a visitor arrives at the guardhouse the security personnel will call person who the

visitor has an appointment with.

d. If there is no reply on the landline and if the person has a short dial, the security personnel

will then call him on his mobile phone.

e. If the security personnel cannot reach this person on his mobile phone, then they will ask

Reception to page for this person.

f. If all above are unsuccessful, then the security personnel must not allow the visitor on site

but are to instead kindly inform the visitor to make an alternative appointment.

g. Where staff member are expecting a visitor on site by a certain time and anticipate being

late for some reason, it is the responsibility of the staff member to inform Security about

the visitor in order to avoid any inconvenience.

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Regarding access control within the Campus, each staff member is to be issued with an Access

Control Card. Each Access Control Card allows access to only those parts of the Campus for

which that staff member is authorised to access.

2.2 Waste Management

Health Care Risk Waste (HCRW), Health Care General Waste (HCGW), including recyclables, as

well as trade effluent and vehicle workshop effluent are generated as part of the SANBS

operations. Waste types are classified, segregated and securely stored in several designated

waste transfer facilities or “transfer stations” within the Campus prior to disposal through

independent service providers. Trade effluent is disposed of into the municipal sewerage

system as permitted. During expansion / maintenance activities within the Campus, excess

inert builder’s rubble and inert spoil material is deposited as backfill into the existing fill

platform.

The Waste Management Hierarchy as illustrated in Figure 2 below has been extracted from

The SANBS Waste Management Guidelines for HCRW and HCGW (INF-SEP-012 Rev0 attached

in Appendix A), and includes prevention, minimisation, reuse, recycling, energy recovery and

disposal.

Figure 2: SANBS Waste Management Hierarchy

2.2.1 Health Care Risk Waste

Health Care Risk Waste (HCRW) generated as part of SANBS and NBI operations within the

SANBS Pinetown Campus comprises anatomical waste, chemical waste, infectious waste,

sharps and softs waste and pharmaceutical waste. HCRW is generated, segregated and

temporarily stored in several waste transfer facilities or “transfer stations” within the Campus,

as per set SANBS procedures. From here the HCRW is periodically removed by independent

waste service providers, disposed of and / or treated as necessary. Safe Disposal Certificates

are received by the independent waste service providers.

HCRW is managed on Campus through the waste management procedure set out in SOP-HSE-

007 Rev0 Waste (HCRW & HCGW) and Environmental Management Plan (Appendix B).

The purpose of this procedure is to ensure traceability of HCRW from the generation of the

waste to the safe disposal of the waste (Cradle to Grave). This procedure applies to all SANBS

operational work areas responsible for the generation of waste and disposal of waste.

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The HCRW classification, segregation and storage procedures as well as detail regarding the

independent service providers and disposal methods are detailed in Appendix C.

Safe Disposal Certificates are received from the service providers and kept for one year in the

work area as well as archived off-site indefinitely. Recent Safe Disposal Certificates are

included in Appendix D.

2.2.2 Health Care General Waste

Health Care General Waste (HCGW) is the portion of waste that poses a minimum degree of

risk to human health and the environment, i.e. from administrative and housekeeping

activities, for example paper, pens, food packaging, etc. The packaging for HCGW is

transparent and is classified as recyclable waste. HCGW is generated, segregated and

temporarily stored in several waste transfer facilities or “transfer stations” within the Campus,

as per set SANBS procedures. From here the HCGW is periodically removed by independent

waste service providers, disposed of and / or treated and / or recycled as necessary.

The HCGW classification, segregation and storage procedures as well as detail regarding the

independent service providers and disposal methods are detailed in Appendix C.

2.2.3 Waste Transfer Facilities

In addition to the requirements of SOP-HSE-007 Rev0 Waste (HCRW & HCGW) and

Environmental Management Plan (Refer to Appendix B), the following specifications are

provided for waste transfer facilities within the SANBS Pinetown Campus:

a. Waste transfer facilities are to be built storage areas that are specifically designated for

temporary waste storage.

b. Each transfer facility is to feature clear signage outside the facility that indicates that

biohazardous and / or hazardous chemical waste is stored within.

c. Each transfer facility is to be secured with a lockable gate, and no unauthorised entry is

permitted.

d. Transfer facility storage areas must be waterproof and maintained in good condition.

e. Loading / off-loading areas will comprise impermeable surfaces to prevent infiltration and

capture run-off accordingly.

f. Transfer facilities must feature excellent lighting (such as sealed fluorescent lighting), be

ventilated and vermin-proof.

g. A hand washing facility with hot and cold and anti-microbial sanitizer must be present in

each transfer facility.

h. A washing tap and hose, as well as central floor drain must be present in each transfer

facility, or other suitable method that enables period wash-down of the facility with

suitable capture of the resulting effluent.

i. HCRW is to be weighed and stored in designated areas of the transfer facilities. This HCRW

is to be removed for treatment / disposal by independent waste service providers.

j. HCGW must be stored separately from HCRW whilst in the transfer facility storage areas.

k. A functioning bulk spill kit and biological / chemical spill kit must be in place at all times.

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2.2.4 Fill Platform Management

Use of the Fill Platform is to be managed to meet the following objectives:

a. A geotechnical investigation of the load baring capacity of the downslope gabion structure

is to be conducted prior to the deposition of any further material.

b. Only inert building rubble and inert spoil material is to be deposited.

c. The deposition of fill material is to avoid, and where this is not possible, minimise,

disturbance to areas with indigenous trees.

d. Deposition of fill material is to occur only landwards of the existing gabion stabilisation, and

thus not affect the watercourse.

e. The available platform area is to be efficiently utilised.

The following care and maintenance measures will be implemented in order to prevent

potential contamination and alteration of natural drainage lines and associated riparian

ecosystems:

a. Exposed area is to be rehabilitated with topsoil and naturally occurring vegetation.

b. Exposed topsoil is to be re-vegetated with a mix of indigenous grasses and indigenous, fast

growing trees (where appropriate) to ensure soil binding and prevent erosion.

c. Invasive plant species will be controlled through removal and/or eco-friendly herbicides.

d. Erosion and platform stability is to be monitored monthly during monthly waste inspections

and addressed to ensure that the fill platform is stable and that the watercourse is not

affected. In the event of erosion or instability, possible remediation methods include the

placing of sand bags, hessian sheets and retention or replacement of topsoil and

vegetation, or in severe cases, the installation of rock gabions. Appropriate structural and

biodiversity specialists will be consulted where necessary.

e. Monthly monitoring (during monthly waste inspections) of surface runoff as well as

potential seepage (if present) from the fill platform will be conducted.

• Should surface runoff contaminants be identified, these will be and removed (e.g.

hydrocarbons, high silt load etc.).

• Should contaminated seepage be identified, an appropriately qualified specialist will be

appointed to test for and remove potentially contaminated materials (disposal

certificates will be obtained).

2.2.5 Trade Effluent

Effluent resulting from the human plasma process and sluice area (SLS) is discharged into the

municipal sewerage system as per the local municipality permit requirements. A copy of the

permit is included in Appendix E.

2.2.6 Vehicle Workshop Effluent

Runoff from the vehicle wash bay and servicing area is collected and channelled into sludge

tanks within the Campus. An independent service provider removes and disposes of the sludge

and a Safe Disposal Certificate is received.

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2.2.7 Waste Facility Effluent / Run-off

Effluent will be generated occasional wash down of activity component 1a. Biohazardous

Waste Transfer Facility and activity component 1c Biohazardous and Chemical waste Transfer

Facility. Effluent resulting from the wash down as well as from potential run-off will be

channelled into the on-Campus Sludge Tanks for disposal at licensed facility. Clean stormwater

will be directed around the waste transfer facilities and no contaminated effluent will be

allowed enter storm water systems and / or watercourses. A water audit will be commissioned

that will investigate, amongst other factors, the effluent discharge streams and stormwater

drainage within the Campus, as well as inspection of operational areas, washbays and waste

transfer facilities. Potential pollution pathways will be identified and mitigation measures

recommended and implemented if necessary in order to comply with the above commitment

and the principles of clean and dirty water separation.

2.3 Transportation Safety

Transportation safety is managed through the CP-TRA-002 Transportation Safety Procedures

contained in Appendix F. These procedures are implemented in order to safely manage the

transportation of goods, dangerous goods, materials and people in compliance with relevant

legislation and other requirements. These procedures are applicable to all SANBS work areas

and courier companies used by SANBS.

2.4 Dispatching of Products and Goods

The dispatching of products and goods is managed through the SOP-TRA-001.0 Dispatching

Products and Goods using a Courier Waybill procedures contained in Appendix G. The purpose

of this procedure is to ensure that the courier waybill is completed correctly and details all the

relevant information. This procedure covers the completion of all courier waybills and applies

to all SANBS staff dispatching products and goods using the courier service.

2.5 Incident Management Procedures

Incidents that may potentially occur during SANBS operations are managed through SOP-HSE-

003 Safety, Health and Environment Incident Management procedures contained in Appendix

H.

The purpose of this procedure is to describe the response to potential fire, spillage and any

other unusual incidents or emergency situations (which may include suspicious object / parcel,

bomb threat, suspicious person, damage to property, flood/bush fire and radiation

emergencies) and to provide in time emergency response plan of action for the prevention

and mitigating the impact on people, environment and business. The effectiveness of this

procedure is to be tested annually through emergency evacuation / fire drills. Due to the

nature of this procedure, individual’s perception cannot be defined, but must be considered in

interpreting the different aspects of the various unusual incidents. This procedure is just a

guide on management of incidents; however the details must be laid down on area or site

specific procedures. The procedure applies to employees, temporary employees, contractors

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and visitors of SANBS. This includes Head office, Zone Processing Centres, Blood Banks, Fixed

Site Clinics and mobiles.

Should a potentially significant and uncontained spill event occur, the following steps will be

taken:

1. Containment and remediation actions detailed in SOP-HSE-003 to be implemented as

far as effectively possible.

2. The DWA, local municipal pollution control department and other relevant authorities

will be notified of the incident.

3. Appropriate spillage, soil, water or environmental specialists will be appointed to

determine the extent of potential contamination and to provide recommendations for

remediation.

4. Remediation actions will be implemented as necessary and in consultation with the relevant regulatory authorities.

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3. Potential Future Maintenance Activities

Where existing facilities, structures or infrastructure within the Campus requires maintenance,

due consideration is to be given to the environment in which the maintenance activity is

proposed. This may take the form of a Section 28 Duty of Care assessment (in terms of NEMA),

or through an Environmental Impact Assessment (EIA) (in terms of the EIA Regulations).

Maintenance is defined in the EIA Regulations, 2010, to mean the reconstruction of the same

facility in the same location, with the same capacity and footprint.

Such maintenance activities should be screened against the relevant EIA Regulations and any

other relevant legislation as a precautionary measure prior to commencement. It is however

likely that maintenance activities, as defined in the EIA Regulations (2010), will not require

environmental authorisation prior to commencement, yet it is recommended that the results

of the screening exercise be submitted to the relevant environmental competent authority to

confirm such.

The general construction control guidelines contained in section 5 should be consulted, and

elements of the guidelines can be voluntarily implemented as feasible and practical, when

conducting maintenance activities.

4. Potential Future Construction and / or Expansion Activities

Where the construction of new facilities, structures or infrastructure and / or expansion of

existing facilities, structures or infrastructure is planned for the Campus, due consideration is

to be given to the environment in which the construction and / or expansion is proposed. This

may take the form of a Section 28 Duty of Care assessment, or through an Environmental

Impact Assessment (EIA).

Construction is defined in the EIA Regulations, 2010, to mean the building, erection or

establishment of a facility, structure or infrastructure that is necessary for the undertaking of a

listed or specified activity but excludes any modification, alteration or expansion of such a

facility, structure or infrastructure and excluding the reconstruction of the same facility in the

same location, with the same capacity and footprint. Expansion is defined in the EIA

Regulations, 2010, to mean the modification, extension, alteration or upgrading of a facility,

structure or infrastructure at which an activity takes place in such a manner that the capacity

of the facility or the footprint of the activity is increased.

Such construction and / or expansion activities need to be screened against the relevant

Environmental Impact Assessment (EIA) Regulations and any other relevant legislation (refer

to section 2) and may require environmental authorisation prior to commencement.

The general construction control guidelines contained in section 5 are supplied as a best

practice example and must inform construction and / or expansion activities.

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5. General Construction Control Guidelines

5.1 Environmental Control Officer

It is recommended that the SHEQ Co-ordinator be responsible for the weekly on-site

compliance monitoring and monthly reporting of the environmental requirements, during the

potential future construction / expansion activities, as per the provisions contained within this

EMP. Alternatively, the SHEQ Co-ordinator may appoint an appropriate member of the Safety

and Environment Department to oversee these duties. This responsibility should be assigned

prior to commencement of any land clearing or construction / expansion activities.

Upon failure by the Contractor and / or his sub-contractors and employees to show adequate

consideration to the environmental requirements of this contract, the SHEQ Co-ordinator may

recommend that the Engineer issue non-compliance penalties and/or have the Contractor's

representative or any employee(s) removed from the site and/or work suspended until the

matter is remedied. No extension of time will be considered in the case of such suspensions

and all costs will be borne by the Contractor. The SHEQ Co-ordinator is also responsible for

monitoring and enforcing the guidelines within the EMP and the issue of penalties; this being

done through the Engineer.

5.2 Contractor’s Responsibility and the Polluter Pays Principle

The provisions contained within this EMP are binding on all Contractors, sub-contractors, and

personnel on the property. In the event of any unnecessary environmental damage caused by

any action, process or negligence of the Contractor, or any personnel under the Contractor’s

employ or commission, it is the responsibility of the person who caused the damage to rectify

and rehabilitate the affected environment at own cost, in line with the ‘polluter pays’

principle. The Contractor is to immediately notify and report any and all infringements on the

conditions of the EMP to both the Engineer and SHEQ Co-ordinator.

5.3 Environmental Awareness Training for Site Personnel

All contractor teams involved in work on the Development are to be briefed by the

Contractor’s site representative on their obligation towards environmental controls and

mitigation and prevention methods in terms of this EMP prior to the start of the on-site work.

The briefing will usually take the form of an on-site talk and demonstration by the Contractor.

The education / awareness programme should be aimed at all levels of management within

the Contractor team and the SHEQ Co-ordinator can assist upon request (See Appendix I:

Environmental awareness ‘Do’s & Don’ts’ multilingual summary sheets).

5.4 Communication Procedures

5.4.1 Site Instruction Book

The site instruction book will be used for the recording of general site instructions as they

relate to the works on site. It will also be used for the issuing of stop work orders for the

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purposes of immediately halting any particular activities of the Contractor regarding an

environmental risk on hand.

5.4.2 Environmental Control Monitoring Reports

The purpose of Environmental Control monitoring reports will be to record the comments of

the SHEQ Co-ordinator or assigned member of the Safety and Environment Department for

presentation at the monthly site meetings, or on an as needed basis and as they relate to

activities on the site. Each of these reports will be made available to the Engineer. These

should also be available to the authorities for inspection or upon request. Site meeting

minutes must reflect environmental queries, agreed actions and dates of eventual compliance.

These minutes may form part of the official environmental record.

5.4.3 Environmental Method Statements

Method statements from the Contractor are required for specific sensitive actions on request

from the SHEQ Co-ordinator. The method statement is a ‘living document’ in that

modifications are negotiated between the Contractor and SHEQ Co-ordinator / Engineer, as

circumstances unfold. All method statements will form part of the EMP documentation, and as

an extension of the EMP, are subject to all terms and conditions contained within the EMP

main document (see Appendix J: Environmental Method Statement).

A method statement details the scope of the intended work in a step-by-step description in

order for the SHEQ Co-ordinator and Engineer to understand the Contractor’s intentions. The

SHEQ Co-ordinator and Engineer may then assist the Contractor in devising any specific

mitigation measures for the intended work. The Contractor must submit a method statement

to the satisfaction of the SHEQ Co-ordinator, using the format provided that should clearly

indicate the following:

What: a brief description of the work to be undertaken;

How: a detailed description of the process of work, methods and materials;

Where: a description/sketch map of the locality of work (if applicable); and

When: the sequencing of actions with due commencement dates and completion date

estimates.

The Contractor must submit the method statement upon request before the relevant

construction activity is due to start. Work may not commence until the method statement has

been approved by the SHEQ Co-ordinator.

5.4.4 Environmental Auditing

As per the Procedures stipulated in SOP-HSE-007 Rev0 Waste (HCRW & HCGW) and

Environmental Management (attached in Appendix B):

• Monthly waste inspections will be conducted at SANBS sites by Waste Controllers.

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• Quarterly waste inspections and Environmental Monitoring will be conducted by SHEQ

Co-ordinators.

• Annual emission and effluent (pollution) monitoring will be conducted by independent

specialists.

In addition to internal auditing and reporting requirements, interim and final environmental

audit reports may be required by the Department of Environmental Affairs and / or relevant

authorities, as a verification mechanism detailing compliance with the conditions of the

Environmental Authorisation and EMP, as well as the effectiveness of the Environmental

Management Objectives.

5.4.5 Record Keeping

All records related to the implementation of this EMP (e.g. site instruction book, method

statements, environmental control monitoring reports, interim environmental audits and

penalties) must be kept together in an office where it is safe and can be retrieved easily. These

records should be kept for a minimum of two years after submission of the final audit report

and should at any time be available for scrutiny by any relevant authorities. Photographs will

be taken of the site prior to, during and immediately after the commencement of each phase

of the Development to provide a benchmark visual reference. These photographs should be

stored with other records related to this EMP.

5.4.6 DWA Notification

Department of Water affairs (DWA) to be informed in writing of all future construction /

expansion activities proposed for the Pinetown Campus, prior to commencement of such

activities.

5.5 Environmental Management of Construction Activities

5.5.1 Contractor’s Camp

There should be a single Contractor’s camp for use by all Contractors involved with the

construction / expansion activities of the Development; for the provision of staff facilities; and

the storage of all materials and equipment. All mechanical equipment and work vehicles used

on site should be stored, serviced and refuelled only at designated areas within the

Contractor’s camp. The most suitable site must be confirmed by the Project Manager to the

satisfaction of the SHEQ Co-ordinator and should not be situated near to any environmentally

sensitive area.

5.5.2 Use of Local Labour

It is suggested that local labour is used during the Pre-construction and Services Construction

phase where possible. Monthly records must be kept of all local labour including that of any

subcontractors.

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5.5.3 Protection of Natural Environmental Features and Heritage Resources

Prior to commencement of any earthworks or construction activities, a suitably qualified

landscape specialist should conduct a thorough rescue of the existing viable indigenous

vegetation on site that may be suitably re-incorporated into the Development. When rescuing

indigenous plants, particular attention must be paid to any sensitive ecological corridors and /

or wetland systems present. Rescued vegetation should be suitably transported to a nursery

where due care will be taken of the vegetation until its replanting.

Indigenous plants and / or wild animals (including reptiles, amphibians, mammals and birds

etc.) may not be damaged or harmed. Any indigenous vegetation to be removed from the site

as part of the Development requirements must be discussed with the SHEQ Co-ordinator prior

to removal. This includes trees where there is doubt regarding identification and / or status as

an indigenous species. Cleared indigenous vegetation may be separately stockpiled for use as

mulch during rehabilitation. All incidents of harm to any animal or natural vegetation (apart

from the agreed areas) must be reported to the SHEQ Co-ordinator. It is recommended that all

alien species are to be removed from the site so as to prevent proliferation.

No structures older than 60 years, or parts thereof, are allowed to be demolished, altered or

extended without a permit from Amafa KZN. Should heritage resource be discovered during

earthworks, work will immediately be halted and the finding will be reported to Heritage KZN.

Work will only commence once the situation has been assessed and management measures

put in place by a suitably qualified heritage specialist and in consultation with Heritage KZN.

5.5.4 Demarcation of the Site

The site must be suitably demarcated prior to the commencement of construction activities.

Should high sensitivity environmental features such as wetland areas, watercourses, protected

vegetation, indigenous vegetation, and / or other sensitive features be present, a “no-go”

area plan may be compiled which details specific ‘go’ and ‘no-go’ areas on the site, as well as

agreed working footprints, buffers and other significant demarcation details as necessary.

Demarcation may take the form of wire fencing, orange plastic netting, shade-cloth fencing, or

other suitable demarcation type. No construction may commence near to sensitive areas

before demarcation has been erected. All demarcation must be securely erected to ensure

that it cannot come loose, and is to be maintained until all construction activities have been

completed and the associated risk of damage to the surrounding area has passed. Access

routes and storage areas should be identified by the Contractor and approved by the SHEQ Co-

ordinator.

As part of site demarcation and prior to conducting any earthworks or construction activities,

the eThekwini Electricity Department will be consulted to determine the presence of

underground electrical services as well as to determine restrictions that may be applicable

within close proximity of overhead power lines. Furthermore, any relocation of electrical

services, if required, will be conducted at the developers’ expense.

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5.5.5 Site Access

Site access should be monitored and controlled and all access routes should be clearly

demarcated in order to minimise environmental impacts. A constant regard must be taken to

safety and dangerous areas should be adequately cordoned off to prevent accidental injury.

The movement of vehicles on the site should be confined to clearly demarcated access routes

and existing roads should be used where approved by the Engineer. Any deviation should first

be approved by the SHEQ Co-ordinator, in consultation with the Engineer. No disturbance to

areas of sensitivity. The Contractor should ensure that vehicles leaving the site are clean and,

wherever possible do not deposit mud and any other earth material on road surfaces.

5.5.6 Establishment of Working and Storage Areas

Working and storage areas need to be demarcated during site establishment. All construction

activities on site, including the storage and stockpiling of materials, should be contained within

these identified and established work and storage areas.

5.5.7 Establishment of Maintenance and Service Areas

Maintenance and service areas should be demarcated during site establishment and all

maintenance and service activities contained so as to avoid any contamination of soil and / or

water. All vehicles, equipment, fuel and petroleum services and tanks should be maintained in

a good condition that prevents leakage and possible contamination of soil or water supplies.

Refuelling areas should be bunded and lined to prevent spilled fuels and oils from

contaminating the ground or water. It is suggested that as a minimum, sandbags should be

placed surrounding the bulk fuel supply tank. The floor of the area is to be lined with plastic

and a layer of sand of approximately 50mm is placed on top of the plastic. Automatic shut-off

nozzles are recommended on all dispensing units.

The park and service area should be treated with a suitable hydrocarbon absorption or

remediation product. Absorbent spill mop-up products should to be on hand (Drizzit and

products from Enretech for instance). All servicing should be done with a drip tray present to

prevent accidental spillage of oils and fuels. A suitable leak proof container for the storage of

oiled equipment (filters, drip tray contents and oil changes, etc.) should be established. All

spills to be immediately contained, reported to the SHEQ Co-ordinator, and dealt with in terms

of the provisions of integrated waste management and pollution control as detailed in

sections 5.5.24 of this EMP, with reference to section 2.5.

5.5.8 Fuels and Flammable Materials

Fuels and flammable materials should be stored in suitably equipped storage areas

demarcated within the Contractor’s camp. These areas must comply with general fire safety

requirements. No fuel may be stored within drainage lines or areas. Impervious lining

materials should be used in these storage areas to prevent contamination of the ground in the

event of spillages or leaks, and automatic shut-off nozzles should be used on all dispensing

units. Quantities of fuels and flammable/hazardous materials stored on site should be

appropriate to the requirement for these substances on site.

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Fuels and oils should be safely located out of harm’s way from the elements. No fuel / oil

containers may be left unattended within drainage areas. All open containers containing used

oil, etc., should be kept under roof or have adequate water tight lids. All spills to be

immediately contained, reported to the SHEQ Co-ordinator, and dealt with in terms of the

provisions of integrated waste management and pollution control as detailed in sections

5.5.24 of this EMP, with reference to section 2.5.

5.5.9 Appropriate Use of Machinery

The Contractor shall at all times carefully consider what machinery is appropriate to the task

while minimising the extent of environmental damage. The Engineer or SHEQ Co-ordinator

may order the removal of equipment that is causing continual environmental damage (e.g. by

leaking oil or diesel) until such equipment has been adequately repaired. All spills to be

immediately contained, reported to the SHEQ Co-ordinator, and dealt with in terms of the

provisions of integrated waste management and pollution control as detailed in sections

5.5.24 of this EMP, with reference to section 2.5.

5.5.10 Care of Existing Services

Care and due consideration should be taken of existing services, new service routes and

service construction methods and restrictions. This aspect is often overlooked causing

unnecessary environmental impact and costs.

5.5.11 Top Material and Stockpiling

Prior to commencement of construction activities, top material should be stripped from work

sites and separately and securely stockpiled, in a manner that prevents contamination of the

topsoil. The topsoil can later be used in rehabilitation.

5.5.12 Earthworks

Any major earthworks with heavy machinery (e.g. bulldozers) should be under constant

supervision and operators are to be aware of all environmental obligations, as there is

increased potential to damage the surrounding environment. The use and excessive

movement of heavy machinery around identified sensitive slopes should be avoided. A

method statement may be required from the Contractor prior to commencement of

earthworks. The material removed from all earthworks should be securely stockpiled in a

suitable site to prevent surface runoff and erosion. Stockpiled soil left over may be used in the

Rehabilitation phase or for landscaping purposes, provided the soil does not contain seeds of

invasive plant species.

5.5.13 Blasting / Drilling

In the event that blasting or rock drilling is required, the Contractor should take all necessary

precautions to prevent damage to special features and the general environment, which

includes the removal of flyrock. Environmental damage caused by blasting / drilling shall be

repaired at the Contractor’s expense to the satisfaction of the SHEQ Co-ordinator and

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Engineer. No blasting may be done on Sundays. Adequate warning should be provided prior to

all blasting to all site staff and neighbours. All-clear signals should also be clearly given. The

Engineer and SHEQ Co-ordinator should be given 24-hour notice before blasting events.

5.5.14 Top Material and Stockpiling

The Contractor should take appropriate and active temporary and permanent measures to

prevent erosion resulting from their own works, operations and activities as well as

stormwater control measures, to the satisfaction of the SHEQ Co-ordinator / Engineer.

Restoration costs will be deducted from the Contractor’s account, should these measures not

be reasonably implemented. Aspects normally covered in construction contracts in terms of

“protection of works” are standard and are not to be billed or confused with any details

covered under environmental requirements.

During construction activities, the Contractor should protect areas susceptible to erosion by

installing all the necessary temporary and permanent erosion control measures as soon as

possible. The use of erosion berms, silt traps and pegged down mulch-filled bags is essential in

all exposed areas where there is a risk of accelerated run-off down slopes (especially prior to

expected periods of heavy rain). Mitigation measures can include cut-off trenches, straw

stabilising, brush packing etc. In the case of general exposed road edges, suitable organic

mulch together with a fast-establishing grass seed can be applied to exposed areas on the road

edges. Seed must be applied as soon as possible after disturbance while the soil is loose and

then covered with at least a 5cm layer of mulching material in order to keep the seed moist.

Stormwater control measures shall be taken as necessary to prevent surface water from being

concentrated in streams and from scouring the slopes, banks or other areas. All such measures

must be discussed with and approved by the SHEQ Co-ordinator / Engineer.

5.5.15 Construction Materials

An effort should be made to choose environmentally-friendly construction materials wherever

possible and feasible from financial and engineering quality perspectives. Construction

materials should be prepared at the relevant batching plant wherever possible, to enable any

negative environmental effects of cement and other substances for instance, as well as the

resulting effluent, to be more easily managed.

5.5.16 Cement Works

All cement mixing should preferably be conducted off-site. If possible and appropriate, ready

mix concrete should be used. Where this is not possible, mixing areas are to be carefully

situated and demarcated in consultation with the Engineer / SHEQ Co-ordinator. All mixing

areas should be bunded to avoid spillage of waste water. Cement contaminated water may

not enter any natural or man-made water system and should not be allowed to be absorbed

into the soil. Preventative measures include establishing sumps from where contaminated

water can be either treated on-site or removed to an appropriate waste site in terms of the

provisions of integrated waste management and pollution control as specified in sections

5.5.24 of this EMP, with reference to section 2.5.

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Empty cement bags should be frequently collected, and may not be burnt. Empty bags must

be securely stored out of the elements (sun, wind and rain) and within the Contractor’s camp.

Excess or spilled cement should be confined within the demarcated works area and then

removed to an appropriate waste site in terms of the provisions of integrated waste

management and pollution control as specified in sections 5.5.24 of this EMP, with reference

to section 2.5.

5.5.17 Brick Works

Bricks used during construction should be stored within the Contractor’s camp. All excess

bricks in good condition may be collected and stockpiled. Waste from brickwork (e.g. brick

chips) should be collected on a weekly basis and stockpiled within the demarcated site for

builder’s rubble and removed to an appropriate waste site in terms of the provisions of

integrated waste management and pollution control as specified in sections 5.5.24 of this

EMP, with reference to section 2.5.

5.5.18 Wood Works

Sawdust generated from woodwork should be swept up and securely stored against the wind

in a demarcated area of the Contractor’s camp. Stored sawdust should be removed to an

appropriate waste site in terms of the provisions of integrated waste management and

pollution control as specified in sections 5.5.24 of this EMP, with reference to section 2.5.

5.5.19 Plaster Works

Mixing of plaster for plaster work should take place in a demarcated site that has impermeable

lining material to prevent contamination of the ground or natural or man-made water courses

(e.g. trench / sloot or dam). Excess plaster may be collected and stored within the demarcated

site for builder’s rubble and removed to an appropriate waste site in terms of the provisions of

integrated waste management and pollution control as specified in sections 5.5.24 of this

EMP, with reference to section 2.5.

5.5.20 Paint Works

All paints and other painting materials (e.g. thinners) should be securely stored within a

designated site of the Contractor’s camp. Where paints and painting material are used, a

suitably contained drip sheet may be placed underneath the paint works to prevent

contamination of the soil and / or surfaces. Paint and painting materials may not enter any

natural or man-made (e.g. trench / sloot or dam) water system.

The rinsing of paint brushes should take place within a demarcated area approved by the

SHEQ Co-ordinator / Engineer that is not next to any sensitive site. Impervious lining materials

are to be used in these rinsing areas to prevent contamination of the ground in the event of

spillages or leaks. Quantities of paint and painting materials stored on site should be

appropriate to the requirement for these substances on site.

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Paint brushes that are rinsed in thinners should be suitably stored to prevent dripping of paint

/ thinners onto the ground or into any water course. Used / unused thinners should be

collected on a daily basis and securely stored according to the environmental objectives for

fuels and flammable materials as detailed in section 5.5.8. Excess / used thinners must be

removed to an appropriate waste site in terms of the provisions of integrated waste

management and pollution control as specified in sections 5.5.24 of this EMP, with reference

to section 2.5.

5.5.21 Roof Insulation Material

No asbestos roof insulation may be used. Unused roof insulation should be securely stored to

prevent it from blowing away in the wind and removed to an appropriate waste site in terms

of the provisions of integrated waste management and pollution control as specified in

sections 5.5.24 of this EMP, with reference to section 2.5

5.5.22 Discharge of Construction Effluent

All cement effluent from mixer washings, and run-off from batching areas and other work

areas should be contained in suitable sedimentation ponds. Sedimentation ponds shall be

allowed to dry out on a regular basis to allow for solid material to be removed. This material

should be disposed of in terms of integrated waste management and pollution control as

specified in sections 5.5.24 of this EMP, with reference to section 2.5. Strictly no

contaminated effluent (cement powder, oils etc.) from the construction site may enter

watercourses.

5.5.23 Handling of Hazardous Construction Materials

In addition to the pollution and contamination measures detailed in other relevant sections of

this EMP, all site personnel should be made fully aware of the health effects of any potentially

hazardous materials stored on site for the purposes of construction, and the suitable methods

of handling these materials. All storage vessels for construction hazardous materials should be

maintained in a good condition that prevents leakage and possible contamination of soil and /

or water supplies. Such storage areas should be bunded and lined to prevent potential spills

from contaminating the ground or water.

In the event of a spill or contamination event regarding these materials during construction,

the Contractor and / or responsible person on site must immediately inform the relevant

Health and Safety Officer, Engineer, SHEQ Co-ordinator and relevant authorities as necessary.

A suitable containment strategy must then be immediately implemented and the spill material

disposed of in terms of integrated waste management and pollution control as specified in

sections 5.5.24 of this EMP, with reference to section 2.5. Should any environmental damage

occur, it is the responsibility of the Contractor to rehabilitate the receiving environment (See

section 5.2)

5.5.24 Integrated Waste Management and Pollution Control

It is the Contractor’s responsibility to minimise the generation of waste where possible and

implement the reduction, re-use, recycling and disposal of waste where appropriate. General

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waste produced during the construction activities is the responsibility of the Contractor. Waste

such as cement bags, gravel, rubble, cans, plastic, wire, etc. should be stockpiled in the area

demarcated for this purpose, suitably stabilised and secured against the wind. This site should

be approved by the SHEQ Co-ordinator / Engineer. No burying of waste or refuse on site will

be allowed.

The Contractor is responsible for the establishment of a refuse control system that is

acceptable to the SHEQ Co-ordinator. Where construction workers are allowed to eat on the

construction site, other than within the Contractor’s camp, the Contractor should provide

adequate refuse bins at all such places and ensure that they are used. The Contractor should

ensure that refuse, surplus food, food packaging and organic waste are not deposited by his

employees anywhere on the site except in refuse bins. Refuse bins must be weather and

animal-proof.

In cases where significant quantities of recyclable waste are generated on site, it is the

Contractor’s responsibility to implement the recycling effort. Recyclable materials should be

separated out, with separate containers for paper, glass, and plastics and these containers

should be placed near to the site office. The Contractor is responsible for the removal of all

stockpiled recyclable material to a recycling facility on a weekly basis, or as necessary. The

Contractor is responsible for the removal of any solid waste collected on-site to a Municipal

landfill licensed in terms of section 20 of the Environmental Conservation Act, 1989 (Act No. 73

of 1989) or the National Environmental Management: Waste Act (Act No. 59 of 2008), on a

weekly basis or as necessary.

In the event of a spill or contamination event, the Contractor and / or responsible person on

site must immediately inform the relevant Health and Safety Officer, Engineer, SHEQ Co-

ordinator and relevant emergency response authorities as necessary. A suitable containment

strategy must then be immediately implemented.

5.5.25 Dust Control

The Contractor is to take appropriate measures to minimise the generation of dust as a result

of construction works, to the satisfaction of the SHEQ Co-ordinator. On sandy or very dusty

sites, stabilisation and dust control methods on any cleared or exposed sections of the site

include the use of suitable mulched indigenous vegetation which is to be removed from the

site. Alternatively, straw stabilisation or watering can be used. Seed bearing invasive

vegetation should not be used for this purpose. In order to minimise the noise impact, all

construction activities are to be limited to within regular working hours. No construction

activities are to take place on Sundays.

5.5.26 Fire Prevention Measures

No fires may be allowed inside the construction area. Adequate fire fighting equipment should

be available on site, in good working order, and according to the fire hazard present during

construction activities (at least one type ABC all-purpose 12.5kg extinguisher). Any welding,

gas cutting or cutting of metal should only be permitted inside the demarcated working areas

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for this purpose and these areas should be approved by the SHEQ Co-ordinator. The

Contractor shall pay the costs incurred to organisations called to put out any fires started by

him. The Contractor shall also pay any costs incurred to reinstate / rehabilitate burnt areas as

deemed necessary by the Engineer and SHEQ Co-ordinator.

5.5.27 Toilets

The Contractor should provide suitable sanitary facilities near his offices and all construction

sites for his staff. A minimum of one toilet should be provided per 15 persons at each working

area or as stipulated by local authority or other relevant legislation. Toilets should be of a neat

construction and have doors and locks. Toilets should be secured to prevent them blowing

over. Sanitation provision and servicing should be to the satisfaction of the Engineer. The

Contractor shall ensure that toilets are emptied before any builders’ holidays.

5.5.28 Stabilisation and Rehabilitation of Construction Site

The Contractor is responsible for the stabilisation of all areas disturbed during construction

activities. This includes all road reserves, pipeline routes, embankments, haul roads, exposed

slopes and the Contractors’ camp. Stabilisation must be completed prior to rehabilitation

taking place, although if appropriate, the stabilisation / rehabilitation may occur progressively

in different sections of the site as work is completed. Areas disturbed during construction

must be rehabilitated by the replacing of topsoil and planting of indigenous plant species.

Invasive plant species will be controlled by removal and/or the use of eco-friendly herbicides.

These areas will be monitored by the SHEQ Co-ordinator for erosion and actions will be taken

as necessary should erosion be observed

5.5.29 Site Clean Up

The Contractor should ensure that all structures, equipment, materials and facilities used or

created on site for or during construction activities are removed once the project has been

completed, to the satisfaction of the SHEQ Co-ordinator.

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Appendix A: INF-SEP-012 Rev0 Waste Management Guidelines

(HCRW and HCGW)

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 1 of 9

Registration No. 2000/026390/08

Rethink

(Prevent)

Reduse

(Minimize)

Reuse

Recycle

Energy Recovery

Disposal

Introduction to Health Care Risk Waste (HCRW) and Health Care General Waste (HCGW)

•••• The management of HCRW and HCGW will start with the correct identification, classification,

segregation, packaging, storage, transportation, treatment and safe disposal (HCRW) of the waste.

•••• This guideline will outline the different waste streams and containers for waste generated in SANBS

(HCRW and HCGW) and also how to track and trace HCRW during downtime.

•••• Waste separation is the process of separating waste at the point of generation and keeping it separate

whilst handling, storage, transportation, treatment and disposal.

Health Care General Waste (which includes non-hazardous Wet (non-recyclable) and Dry

(recyclable) Domestic Waste

• HCGW is waste which is not classified as clinical or related waste, and includes paper, plastic, glass,

liquids and organics.

• HCGW is removed by an approved Service Provider on a pre-approved schedule and taken to a

landfill / recycling site.

• Non-Hazardous Wet Waste (Eg. sandwiches, banana peels, etc.) from the kitchen, canteen and

offices is cannot be recycled.

• Non-Hazardous Dry Waste (Eg. paper, glass, plastic, etc.) from the kitchen, canteen will be recycled.

Waste Management Hierarchy

Most Favourable Option

Lease Favourable Option

• Rethink is applicable when you procure a product and ensure that the product has no waste stream,

(e.g. when designing a machine the waste materials should be able to sustain energy for the operation

of the machine).

• Reduce is when the product / equipment is designed to generate a lower rate of waste stream (e.g.

Specialised Blood Bags).

• Reuse is the packaging material of a product purchased which can be reused to package / transport

another existing product (e.g. Nat Testing Reagent outer packing material are used to transport

frozen products).

• Recycling is the recovery of re-usable materials in the waste stream to reduce the cost of raw

materials. (e.g. plastic bags can be re – manufactured into a new plastic bag without using new raw

materials).

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 2 of 9

Registration No. 2000/026390/08

• Energy Recovery is to utilize products from the waste stream that is not recyclable and to generate

energy from it (e.g. tyres are converted into heat)

• Disposal is to discard / throw away / release of any waste material into / on air, land, or water as the

purpose or use has become redundant and are disposed of in a proper process into the environment

without the intention of retrieval.

Health Care General Waste Containers:

Eco-Cylinders Wet Waste Containers

Wheelie Bins

NOTE: HCGW does not require traceability (bar codes).

Health Care General Waste (Recyclable Waste)

• Management HCGW in Blood Banks which are in hospitals and Fixed Donor Clinics will liaise with

the hospital/centre management to dispose their HCGW according to the hospital/centre Waste

Management Procedure.

• If there are no procedures in place, special arrangements for collection and disposal must be arranged

with Admin & Facilities (Zone Admin Co-ordinator).

• Recyclable waste does not require traceability.

When discarding non-hazardous recycled waste, which includes domestic, paper, can, plastic or

glass follow the Waste Colour Code Chart (INF-SEP-001) to select the correct containers.

• Use appropriate waste container.

• For wet waste the bin should be designed with a flip-top lid.

• For dry waste the container can be black with colour coded lid or completely colour coded.

• The containers should be lined with a transparent plastic bag.

• When the bin is full, cleaning contractor or any other designated cleaner to remove full plastic bag

from the bin and line the bin with new transparent plastic bag.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 3 of 9

Registration No. 2000/026390/08

• Cleaning contractor or any other designated cleaner to place the full plastic bag into the designated

wheelie bin provided at the Waste Transfer Station/Holding Area.

• When the wheelie bin is full, the waste removal contractor will collect the waste from the Waste

Transfer Station / Holding area as per the agreed time frame on the contract.

Construction Work:

• Waste generation during project work will be removed by the contractor.

• Approved bins will be provided by the contractor and the cost thereof covered by the contractor.

Maintenance Work:

• Waste generated by the Maintenance Department must be deposited into the colour coded container

provided by S&E Department.

Radioactive, Electronic, Asbestos & any other Hazardous Materials

• For the disposal of radioactive, electronic, asbestos & any other hazardous an appropriate

international hazard label must be used.

• Only trained and approved contractors can handle this type of waste as it requires special handling

and disposal.

• The waste manifest and disposal certificate for the removal and safe disposal of asbestos waste will

be kept by the construction supervisor on file for future reference.

• The waste manifest and safe disposal certificate for the removal and disposal of any other hazardous

material will be kept by the S&E Department.

Paint Tins (Separate Drum), Paint Washings and Oily Sludge (Dark Green Drum):

• Use a separate drum to store the paint tins for disposal.

• When drum / container is full or when period of 90 days lapse notify Waste Controller.

• The Waste Controller will contact the waste contractor to collect full cage / drum, and will supervise

the work checking that the appropriate personal protective equipment are used and that the drums are

labelled according to the hazard class.

HEALTH CARE RISK WASTE (HCRW) HAZARDOUS:

• Pharmaceutical Waste includes expired or discarded pharmaceuticals which includes expired

medicines.

Chemical Waste includes all empty chemical containers that previously contained reagents, expired

reagents, redundant reagents, residual chemicals, broken eutectics (Butane diol eutectics), used

fluorescent tubes and mercury thermometers.

HCRW (CONTAINERS, LINERS AND LABELS):

• A dark green container is used for the discarding of Pharmaceutical Waste.

• A dark green 120ℓ or 240ℓ wheelie bin will be used for discarding of e.g. empty chemical containers.

• A 20ℓ green plastic container will be used for broken / faulty mercury thermometers.

• High Risk Chemical Substances are disposed of according to a pre-approved method (e.g. ethanol in

a steel drum).

• Liner – Yellow Liner for the Green Wheelie Bin and Green Waste Bucket.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 4 of 9

Registration No. 2000/026390/08

Re–Usable Container Disposable Container

Label

LINING AND LABELLING THE WASTE CONTAINERS:

• Line the Waste Container with a yellow liner.

• Attach an appropriate bar coded label INF-SEP-007, on the side of the container.

• Ensure that the label is facing the right side up.

• Do not place the label on Container Logo.

• When re-usable Waste Containers for Chemical Waste are used, place the label on the bag and not

the container.

CHEMICAL WASTE:

• When discarding empty chemical containers and expired chemicals, place the empty chemical

containers and expired chemicals in the correct container.

• Complete HCRW Tracking and Traceability Downtime Record (FRM-SEP-058) and Dangerous

Goods Declaration (FRM-SEP-040).

• The package with the above mentioned forms will be sent to the Waste Transfer Station.

• FRM-SEP-040 will be given to the accredited service provider collecting the chemicals.

• The Waste Manifest will be given to the Waste Controller / Responsible Person by the accredited

Service Provider, and this will be given to the S&E Practitioner.

• At a later stage the accredited Service Provider will distribute the Safe Disposal Certificate to the

S&E Practitioner.

• The S&E Practitioner will scan the Waste Manifest together with the Safe Disposal Certificate on the

Quality Drive in the SHE Folder.

• High Risk Chemical Substances are disposed of according to a pre-approved method (e.g. Ethanol in

a steel drum).

• Broken Mercury Thermometers from the Sites will be double bagged (small yellow bags) and sent to

the Waste Transfer Station.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 5 of 9

Registration No. 2000/026390/08

• Complete FRM-SEP-058 and FRM-SEP-040.

• FRM-SEP-040 will be given to the accredited service provider on collection.

• At the Waste Transfer Station the documents will be kept aside until collection and the package

(yellow bags) placed into a green bucket.

• Fluorescent Tubes will be removed by the accredited Service Provider replacing the fluorescent

tubes on site.

• Works and Maintenance Department will no longer be crushing tubes on site (risk mitigation).

PHARMACEUTICAL WASTE:

• The work areas should forward all expired, Pharmaceutical Waste to the Occupational Health &

Employee Wellness Consultant (HWC).

• All Pharmaceutical Waste is placed in the green pharmaceutical Waste container.

• When the container is full the HWC will inform the accredited Service Provider to collect the

container.

• Complete FRM-SEP-058 and FRM-SEP-040.

• On arrival of the accredited Service Provider collecting the Waste, FRM-SEP-040 will be given to

the Service Provider.

• The Service Provider will insert the Waste Manifest Number on FRM-SEP-058 in the space

provided and give the Waste Manifest to the work area (HWC).

• The Service Provider will send a safe disposal certificate to the HWC upon destruction of waste.

SHARPS WASTE:

• Sharps/Soft Sharps: is waste generated at sites and includes all contaminated needles, plastic

pipettes, capped specimen/test tubes (glass/plastic clinical glass), slides, units attached to needles,

patient samples, wafers, hard plastic instrument tips etc.

SHARPS WASTE CONTAINERS, LINERS AND LABELS:

• Sharps Container is a rigid yellow disposable and reusable container with a tamper proof lid.

• It is recommended best practice to utilize re-usable containers where possible.

Single use Containers (Disposable)

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 6 of 9

Registration No. 2000/026390/08

Reusable Sharps Container

LINING AND LABELING SHARPS CONTAINERS:

• Sharps container does not require a liner.

• Attach a bar coded label HCRW Sharps Waste Container Label (INF-SEP-005) on the side of the

container.

• Ensure that the label is facing the right side up.

• Do not place the label on the Container Logo.

• When re-usable sharps containers are being used cable tie the label to the handle of the container.

Label

HEALTH CARE RISK WASTE (HCRW) (INFECTIOUS AND ANATOMICAL WASTE):

Infectious Waste:

• Infectious Waste includes used gloves, plasters, cotton swabs, and laboratory coats.

• A wheelie bin is a red rigid plastic container with two wheels at the back and a handle, which comes

in the following volumes 120ℓ and 240ℓ.

• Re-usable Box set is a red rigid plastic square container which comes in the following volumes 70ℓ

and 110ℓ.

• It is recommended best practice to utilize re-usable containers where possible.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 7 of 9

Registration No. 2000/026390/08

Infectious Waste Container (Reusable) Label

Anatomical Waste:

• Anatomical Waste includes defective blood units; liquid waste (e.g. used copper sulphate and

contaminated saline), empty/expired reagent cells and uncapped specimen and test tubes.

• Anatomical Waste Container is a red rigid disposable red bucket. (Single Use / Disposable

Containers).

Anatomical Waste Container Disposable Waste Container

LABELLING AND LINING HCRW CONTAINERS (INFECTIOUS AND ANATOMICAL):

• Attach an appropriate bar code label HCRW Anatomical and Infectious Waste Container Label (INF-

SEP-006) on the side of the container.

• Ensure that the label is facing the right side up.

• Do not place the label on Container Logo.

• When using re-usable Infectious Waste Containers (Wheelie Bins and Reusable box sets), place the

label on the liner, or place the label on the lid of the Container.

• Anatomical and Infectious Waste Containers require a liner

Down Time Process:

• For Electronic Traceability of Waste refer to CS Tracker Training Guide (INF-SEP-014).

Ordering Waste Containers:

• The Responsible person will order the correct containers using Waste Container and Consumables

Order (FRM-SEP-073) from the approved service provider.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 8 of 9

Registration No. 2000/026390/08

Ordering Waste Container Labels:

• The responsible person will order the Waste Container Labels from Stores Department.

Lining the Container:

• Line the container with the appropriate liner.

Labelling of Container:

• The responsible person will label the container with the appropriate barcode label.

Segregation of Waste: (Using the required PPE)

• Segregate the Waste at source according to waste streams identified.

Discard Health Care Risk Waste: (Using the required PPE)

• Discard Waste into the prepared containers at source.

Closing Containers: (Using the required PPE)

• Hazardous waste (Chemical and Pharmaceutical Waste) tighten / close the lid.

• Sharps Waste containers must be closed / tightened as this is a tamper proof lid.

• For infectious and anatomical waste, pull up the liner in a twisting movement and cable tie the liner.

• Push down the package with the lid.

• Secure and lock the lid in position.

Recording the Bar-Code Label and Completing HCRW Traceability Record:

• Remove Bar-code strip attached at bottom of the Waste barcode label and attach the label to HCRW

Tracking and Traceability Downtime Record (FRM-SEP-058), under the barcode number section.

• Complete the Location (Work Area), type of container, volume of container (Waste Company),

person who sealed container and the date.

Storage of Waste:

• Waste Transfer Station should be a secure locked area.

• Holding Area should be a demarcated holding area in the work area.

• The work area will complete FRM-SEP-058 prior to storing the Waste.

• Waste containers are weighed and the mass for each container is recorded on FRM-SEP-058.

• Weighing will only take place at the areas where there is a Waste Transfer Station.

Removal of Health Care Risk Waste from Waste Transfer Station and Holding Area:

• On arrival of the Waste Disposal Company at the Waste Transfer Station or Holding Area, the Waste

Controller / Responsible Person will complete FRM-SEP-058, inserting all the necessary information

required.

• The Waste Controller / Responsible Person at the Waste Transfer Station / Holding Area will

complete

FRM-SEP-040 and give it to the driver collecting waste.

• The driver of the Waste Disposal Company will issue a Waste Manifest for waste collected to the

Responsible Person / Waste Controller at the Waste Transfer Station / Holding Area.

• At the end of the month the Waste Disposal Company will ensure that the Safe Disposal Certificates

are sent to the Waste Controller / Responsible Person at the Waste Transfer Station / Holding Area.

• The Waste Controller / Responsible Person at the Waste Transfer station will distribute the Safe

Disposal Certificates to the work areas.

Note: Waybill numbers are only recorded if HCRW is collected by Courier Company.

Waste Management Guidelines (HCRW and HCGW) (Including Down Time Process

INF-SEP-012 REV 0 Page 9 of 9

Registration No. 2000/026390/08

REMOVAL OF WASTE FROM REMOTE SITES / AREAS BY VEHICLE OPERATOR

(SANBS) OR COURIER COMPANY:

• On arrival of the Courier Company collecting the Waste insert the waybill number on FRM-SEP-058

in the space provided.

• When SANBS transport is used no waybill number will be required.

• FRM-SEP-040 will be completed and given to the driver.

• A copy of FRM-SEP-058 will accompany the waste containers to the Waste Transfer Station.

• Vehicle operator / Courier Company collect / load waste from the remote site and transport the waste

to the Waste Transfer Station.

• At the Waste Transfer Station the collected Waste is off-loaded and stored in the appropriate Waste

storage area.

• Refer to removal of Waste at the Waste Transfer Station.

HCRW GENERATED BY MOBILE CLINICS:

Containers and Liners:

• A disposable sharp container may be used for sharps generated by mobiles refer to FRM-SEP-073

for the different sizes.

• It is recommended best practice to utilize re-usable containers where possible.

• A 2.5ℓ or 5ℓ bucket for Anatomical Waste.

• A 30ℓ 100micron bag for Infectious Waste.

• A 240ℓ 100micron bag to place the smaller Infectious Waste bags in at the end of the clinic.

• When returning to the Waste Transfer Station /Fixed Site/Holding Area the labeled bag (240ℓ) will

be placed in a designated wheelie bin.

• Refer to removal of Waste from Waste Transfer Station or Holding area for the completion of the

correct documentation.

Note: All documentation must be kept on site for a year and archived off site indefinitely.

ACCURACY AND RECORDING:

• Supervisor / Designated Person to check the accuracy of the generated documentation and report any

discrepancies to the SHEQ Co-ordinator.

EcoAfrica Environmental Consultants

Environmental Management Programme for the South African National Blood Service, Pinetown Campus, Kwazulu-Natal.

35

Appendix B: SOP-HSE-007 Rev0 Waste (HCRW & HCGW) and

Environmental Management

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 1 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

1. Purpose and Scope

1.1 This document describes how to handle, segregate, store, treat and dispose of Health Care

Risk Waste (HCRW) and General Health Care Waste (HCGW) generated by SANBS in a

Safe, Healthy and Environmental friendly manner.

1.2 This document describes the Tracking and Traceability of waste, thereby ensuring that

the waste is managed from Cradle to Grave.

1.3 Health Care Risk Waste is non-recyclable waste and requires tracking and traceability

1.4 Health Care General Waste is recyclable waste and does not require any tracking or

traceability.

1.5 This procedure applies to all SANBS work areas.

2. External References

2.1 National Environmental Management Act (Act 107 of 1998) as amended.

2.2 National Environmental Management: Waste Act (Act 59 of 2008) as amended.

2.3 National Environmental Management: Air Quality Act (Act 39 of 2004) as amended.

2.4 National Water Act (Act 36 of 1998) as amended.

2.5 Minimum requirements for the Handling, Classification and Disposal of Hazardous

Waste (DWAF Series on Waste Management) – including the guidelines for complying

with requirements of landfill site permits (Second Edition 1998).

2.6 SANS 10248: parts1, 2 and 3 Management of Health Care Waste.

2.7 SANS 10400: all applicable parts (Building Regulations-Energy Saving Regulations)

2.8 SANS 10228: The identification and Classification of Dangerous Substances and Goods.

2.9 SANS 452 (Standards for Sharps Containers).

2.10 SANS 204:2011 (Energy Efficiency in Buildings)

2.11 Hazardous Substances Act 15 of 1973.

2.12 National Integrated Waste Management Policy.

2.13 Occupational Health and Safety and Regulations (Act 85 of 1993) as amended.

3. Definitions

3.1 HCRW(Health Care Risk Waste): is human and animal anatomical waste, infectious

human and animal waste, sharps, chemical waste, pharmaceutical waste and radioactive

waste generated by healthcare professionals is classified as hazardous waste.

3.2 HCGW (Health Care General Waste): is a portion of waste that poses a minimum

degree of risk to human health and the environment is classified as non- hazardous waste.

3.3 Waste: is any solid, liquid, or gaseous material that is discarded which can be a by-

product of an operation or process that is no longer required.

3.4 Hazardous Waste (Infectious and Anatomical): includes all blood, associated products

contaminated with blood whether in a dry or liquid form.

3.5 Pharmaceutical Waste: includes all expired and redundant medicines.

3.6 Chemical Waste: includes all containers which previously contained hazardous

chemicals, redundant/residual chemicals.

3.7 Sharps Waste: includes items such as needles, syringes, blades, glass, slides, clinical

sharps (soft sharps) which are capable of causing cuts, abrasions or puncture wounds.

3.8 Dry Waste: is recyclable non-hazardous domestic waste such as plastic, glass, paper,

cardboard, etc.

3.9 Wet Waste: is non-recyclable non-hazardous waste from canteens which includes

sandwiches, banana peels, etc.

3.10 Wheelie Bin: is a rigid plastic container with two wheels at the back with a handle.

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 2 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

3.11 Eco-bin: is a cylinder type plastic container with carry handles.

3.12 SANS: South African National Standards.

3.13 AIA: Approved Inspection Authorities

3.14 Cradle to Grave: is the process whereby Health Care Risk Waste is generated and can

be traced, by identification, segregation, storage, transportation, treatment and disposal.

3.15 Waste Generator: is the person / or site who generates the waste at source according to

the waste streams identified.

3.16 Waste Controller: is the person who is responsible for the monitoring of the waste

process at the Waste Transfer Station.

3.17 Waste Transfer Station: is a temporary on-site storage facility for the intermediate

storage of waste.

3.18 Holding Area: is a demarcated / designated area within the work area prior to the waste

being transferred to the Transfer Station.

3.19 Segregation: is the separation of waste streams at source into the correct waste

categories.

3.20 Traceability / Tracking: are the tools and documentation system which are used for

Tracing and tracking of HCRW.

3.21 MSDS (Material Safety Data Sheet): is a document designed to provide employees and

emergency personnel with proper procedures for handling or working with a particular

substance.

3.22 Waste Manifest: is a Waste Document that serves as proof of the amount of waste

collected by the accredited Service Provider

3.23 Dangerous Goods Declaration: is a legal transport document declaring the description

and nature of goods.

3.24 Safe Disposal / Destruction Certificate: is a waste document that serves as proof that

the waste collected was treated, disposed and destroyed, by the accredited Service

Provider.

3.25 Treatment and Disposal of Waste: is the process whereby the waste is treated and

dispose safely by the accredited Service Provider.

3.26 Waste Contractor: is a company contracted to manage one or all aspects of SANBS.

3.27 Green Procurement: is a selection of products and services which minimizes the impact

of the products and services on the environment in order to reduce the carbon emissions

and the carbon footprint of the products.

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 3 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

4. Safety, Health and Environment

Hazards / Risks Identified Operational Controls

Exposure to Hazardous Biological Agents

and Hazardous Chemical Substances (e.g.

Eye splash and needle stick injuries.)

Engineering controls

• Waste handling and storage facilities design.

• Separation of dirty run-off areas from storm water

systems.

• Impermeable surfacing of Waste handling and

storage facilities.

Risk Mitigation Controls:

•••• Correct packaging, segregation, storage and

transportation of waste.

•••• SHE Incident Reporting and Investigation

Procedure (CP-SEP-002)

•••• Emission and effluent monitoring

•••• Monitoring of a legal compliant

•••• Environmental awareness training

•••• Medical Surveillance Program (e.g. Hepatitis B

Immunization).

Administrative control

•••• MSDS for Hazards Identified.

•••• Traceability / Tracking system

•••• Waste Manifest

•••• Safe Disposal / Destruction Certificates

•••• SAP Notification System

•••• Environmental Auditing and Risk Assessments

Personal Protective Equipment

•••• Employees should wear applicable PPE to prevent

any exposure to Hazardous Biological and

Chemical agents.

•••• Laboratory coat, gloves, closed shoes / boots

5. Responsibility

5.1 The S&E Manager is responsible for ensuring that this document is reviewed and

revised.

5.2 S&E Department is responsible for the design, implementation and monitoring of a

legally compliant Waste Traceability and Tracking System for HCRW as well as the

application, registering and monitoring of Environmental permits.

5.3 S&E Practitioners are responsible for elevating all waste deviations to the S&E

Manager and reviewing of the Waste Controller reports and addressing all unresolved

matters.

5.4 SHEQ Coordinators are responsible for quarterly waste inspections of waste transfer

stations in their zone, waste inspections and environmental monitoring during site visits

and elevating unresolved matters to the S&E Practitioners.

5.5 Waste Controllers are responsible for ordering and maintaining of waste containers and

consumables, waste bar code labels from stores and doing waste inspections and

reporting any deviations to S&E Practitioners.

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 4 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

5.6 IT Department is responsible for the implementation and maintenance of the Electronic

Waste Tracking System and the safe disposal of electronic waste generated which will

assist with the reduction of carbon emission and carbon footprints..

5.7 Admin and Facilities are responsible for the implementation of sustainable energy

saving measures related to water, electricity and any other energy sources applicable to

our industry and negotiating applicable rebates with the relevant external stakeholders (eg

ESKOM).

5.8 Purchasing Department is responsible for purchasing labels from the approved Service

Provider and to implement Green procurement.

5.9 Transport Department is responsible for: Implementing and maintaining an energy

efficiency program for vehicles, ensuring that spillages of waste materials during

handling and transportation are prevented and any waste spillage incidents reported to the

S&E Department.

5.10 Works & Maintenance is responsible for: Ensuring that energy saving measures is

implemented and maintained for all machinery, generators and transformers purchased, in

a sustainable manner and where cost effective / sustainable preference should be given to

“Green Procurement”.

5.11 Audit Department is responsible to: Ensure that all approved S&E Service Providers

and their Sub-contractors are audited periodically regardless of their accreditation status.

5.12 Supervisors / Heads of Department / Managers are responsible for ordering the Waste

Containers from approved / accredited Service Provider and HCRW bar code labels from

Stores in the work areas where there are no Waste Controllers appointed. All traceability

documentation relating to HCRW in the work areas must be retained for audit purposes.

Quality Control Department is responsible for the testing and releasing HCRW bar

code labels HCRW Sharps Waste Container Labels (INF-SEP-005), HCRW Anatomical

and Infectious Waste Container Label (INF-SEP-006), HCRW Chemical and

Pharmaceutical Waste Container Label, (INF-SEP-007) as per Waste Container Labels

(SPEC-QCL-014).

5.13 Stores Department is responsible for the availability of sufficient stock as per List of

Critical Commodities, Printed Material and Raw Materials (INF-QMD-001) and user

requirement (minimum / maximum stock levels) and despatch HCRW labels to the work

areas as per Stores SAP Reservations

6. Procedure for Segregation, Discarding, Storage and Disposal of HCRW (Non-

Recyclable) and HCGW (Recyclable):

•••• All HCRW (Non-Recyclable) and HCGW (Recyclable) should be segregated at source.

• The acceptable standard for SANBS is for HCRW to follow SANS 10248: parts 1, 2, and

3 and referring to Waste Colour Code Chart (INF-SEP-001) for correct packaging of

HCRW (non-recyclable) and HCGW (recyclable).

HCRW (Non-Recyclable Waste)

6.1 HCRW (Non-Recyclable Waste) requires tracking and traceability in order to meet the

cradle to grave concept.

6.2 The acceptable standards for SANBS is to adhere to SANS 10248 for the disposal and

treatment of HCRW

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 5 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

6.3 Refer to SANBS Waste Colour Code Chart (INF-SEP-001) for the correct

containerization of HCRW and HCGW.

6.4 Order the waste containers and consumables from the approved / accredited Service

Provider using Waste Containers and Consumables Order (FRM-SEP-073).

6.5 Order barcode labels from Stores.

6.6 Prepare containers according to Waste Management Guidelines (HCRW and HCGW)

(INF-SEP-012).

6.7 Label the container with the appropriate barcode label:

• For the electronic system refer to CS Tracker Training Guide (INF-SEP-014).

• For downtime refer to Down Time Process for Tracking and Traceability of Health

Care Risk Waste INF-SEP-035.

6.8 Scan the labelled container into the system:

• For the electronic system refer to INF-SEP-014.

• For downtime refer to INF-SEP-035.

6.9 Waste must be segregated into the correct containers at source as per INF-SEP-012.

6.10 Discard the waste into the selected prepared, labelled containers.

6.11 Prepare the full Waste Container for safe storage and transportation.

• For the electronic system Refer to INF-SEP-014.

• For downtime refer to INF-SEP-035.

6.12 When the Service Provider collects waste from:

• Holding Area:

o The Waste Manifest will be given to the work area by the Service Provider.

o The Safe Disposal Certificate will be distributed by the end of the month, to the

work area by the Service Provider.

• Waste Transfer Station:

o The Waste Manifest will be given to the Waste Controller / Responsible Person.

o The Safe Disposal Certificate will be distributed by the end of the month, to the

Waste Controller/Responsible Person.

o Waste Controller / Responsible Person will distribute the Waste Manifest and

Safe Disposal Certificates to the work areas.

6.13 SANS Standards 10248:1 detail that HCRW s collection/storage time shall not exceed the

time limit of 72 hours storage at the Waste Transfer Station or Holding Area, otherwise it

may be refrigerated not for longer than 90 days in a sealed container.

HCGW (Recyclable Waste)

6.14 HCGW does not require tracking and traceability therefore the Waste Management

Hierarchy (4 RRRR’s) according to INF-SEP-012 should be applied.

6.15 Select and use the appropriate containers according to INF-SEP-012 and INF-SEP-001.

6.16 Liaise with the hospital (blood banks) or centre management (fixed donor clinics) on

disposing of HCGW according to their waste management procedure.

6.17 Liaise with Admin & Facilities (Zone Admin Co-ordinator) if there are no procedures in

place as special arrangements for collection and disposal of HCGW will be arranged.

6.18 SANBS should not incur any costs as the recycling company will be claiming rebates

from the Government.

6.19 Waste must be segregated into the correct containers at source as per INF-SEP-012 and

INF-SEP-001.

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 6 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions.

6.20 When the bins are full, the cleaning contractor or any other designated cleaner will

remove the full plastic bag from the bin and line the bin with a new transparent plastic

bag.

6.21 The cleaning contractor or any other designated cleaner will place the full plastic bag into

the designated wheelie bin provided in the Waste Transfer Station/Holding Area.

6.22 When the wheelie bins are full, the waste removal contractor will collect the waste from

the Waste Transfer Station / Holding area as per the agreed contract.

6.23 For the disposal of Radioactive, Electronic, Asbestos & any other Hazardous Materials

for no specific colour code are required only the appropriate international hazard label

refer to INF-SEP-012.

6.24 The above will be achieved by the Environmental Management Plan (EMP).

Environmental Waste Management and Monitoring

6.25 SANBS will effectively administer and provide a systematic approach as to protect the

human health and environment from possible harmful effects caused by effluent

discharge, air/pollution/noise, etc.

6.26 Effluent resulting from human plasma process and liquid waste contaminated with blood

(water and saline) is discharged of into the municipal sewerage system as per the permit

of the local Municipality.

6.27 The effluent discharge (at applicable sites) will be monitored monthly by the Waste

Controllers using Waste Inspection Register (FRM-SEP-082).

6.28 Energy Saving methods (green procurement) must be implemented to maintain energy

efficiency when purchasing equipment/machinery etc. in order to reduce the carbon

footprint.

6.29 Water consumption from the borehole (applicable sites only) will be monitored monthly

by the Waste Controller using FRM-SEP-082.

6.30 SHEQ Coordinators will conduct quarterly waste inspections of the waste transfer

stations in their zone using FRM-SEP-082.

6.31 The SHEQ Coordinators will conduct environmental monitoring (Ventilation,

Ergonomics, Lighting, etc.) during site visits using FRM-SEP-082.

Note: Supervisor / Head of Department / Manager to check the accuracy of the generated

Documentation and report any discrepancies to the SHEQ Co-ordinator.

Department Code CP-SEP-007 SAP Number 1009350 Version Number 0

Effective Date Final Approver in SAP Dr C Ingram

Document Controller Date Issued

Waste (HCRW & HCGW) and Environmental Management Plan

FRM-QMD-013

Rev 3 (17/06/11)

Page 7 of 7

This is an authorised document and all authorisations and approvals are traceable on SAP DMS.

Electronic documents may be printed for reference and training purposes. No further control of the

printed document is necessary. The electronic version of a document will override any printed versions

7. Record Documents

8. Internal Referenced Documents

9. Revision Summary

VERSION

NUMBER REVISION DETAILS

0 • New Document - Department Document Codes Changed.

DOCUMENT

NUMBER DOCUMENT TITLE

RETENTION

TIME LOCATION

FRM-SEP-040 Dangerous Goods Declaration 1 year On site

FRM-SEP-058

HCRW Tracking and Traceability Downtime

Record 1 year On site

FRM-SEP-073 Waste Container and Consumables 1 year On site

FRM-SEP-082 Waste Inspection Register 1 year On site

DOCUMENT

NUMBER DOCUMENT TITLE

INF-SEP-014 CS Tracker Training Guide

INF-SEP-001 Waste Colour Code Chart

INF-SEP-012 Waste Management Guidelines (HCRW and HCGW)

INF-SEP-035 Down Time Process for Tracking and Traceability of Health Care Risk Waste

INF-QMD-001 List of Critical Commodities, Printed Material and Raw Materials

INF-SEP-005 HCRW Sharps Waste Container Labels

INF-SEP-006 HCRW Anatomical and Infectious Waste Container Label

INF-SEP-007 HCRW Chemical and Pharmaceutical Waste Container Label

SPEC-QCL-014 Waste Container Labels

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Appendix C: Classification, segregation, storage and disposal of

wastes

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References and Guidelines: SANS 10248:1:2008

SANS 10248:2:2009 SANS 10248:3:2011

SANS 10228 – The identification and classification of Dangerous Substances and Goods.

National Environmental Management Act (107/1993) Environmental Conservation Act (73/1989)

Hazardous Substances Act (15 of 1973) National Waste Act 2008 (as Amended)

Manual for Department of Water Affairs and Forestry 2nd Edition 1998

Hazardous waste (Chemical) Hazardous Waste includes all empty chemical containers that previously contained.

hazardous chemicals, expired chemicals, redundant chemicals, residual chemicals, used fluorescent tubes and mercury thermometers.

Wasteman:

Empty Chemical containers

• This is removed by Wasteman as per agreed schedule.

• Wasteman transport the empty chemical containers to EnviroServ H:h Landfill

Facility, Shongweni, Durban.

• On the arrival at the landfill facility the empty containers are crushed and

buried on ash and treated with lime.

Fluorescent Tubes and Mercury Thermometers

• This is collected from Pinetown site by Wasteman once the containers are full.

• Wasteman collects the containers and transport it to their storage facility in

Bulbul Drive, Durban.

• It is transported from Wasteman Storage Facility to Vissershoek H:H Site in

Cape Town.

• On arrival at the Vissershoek H:H site it is immediately dispose of/treated.

• Mercury thermometers are encapsulated.

• Fluorescent tubes are treated with sodium sulphide sulphar at Vissershoek H:H Landfill.

Contact Persons: Wasteman Heidi Ford Sales Manager

Karen Adams Sales Rep A Division of Wasteman Holdings (Pty) Ltd

101 Bulbul Drive - Chatsworth - 4060 PO Box 32308 - Mobeni - 4060 - Tel: +27(0) 31 460 4600 - Fax: +27(0) 31 460 4646

Email:Karen Adams <[email protected]> Health Care General Waste: Dry Compactable Waste is collected on Monday,

Tuesday, Wednesday and Friday. General Health Care Waste includes paper packing, plastics, glass, etc.

• This is removed from the offices/laboratories by a contracted cleaning

company.

• The waste goes into 2 FEL Containers on site.

• EnviroServ collect the waste twice a week from SANBS Pinetown Campus, by

emptying the skips and removing the waste to their storage facility.

• The dry compactable waste goes to their landfill site.

Contact Person: Enviroserv

Sally Ann Hislop (031-9021526). Email: [email protected]

HCRW Health Care Risk Waste:

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• HCRW is collected from Pinetown site on a Monday, Wednesday and Friday.

• HCRW includes Sharps Waste, Infectious Waste, Anatomical Waste and Pharmaceutical Waste.

• Waste is generated at sites and it includes all blood-contaminated material,

defective blood units, associated blood products, contaminated Personal Protective Equipment and Expired Medicines.

• HCRW are generated, segregated, dispose and treated as per set SANBS Procedures

Sharps and Soft Sharps Waste:

• A Sharps container is a rigid yellow container, which is a disposable, tamper proof container.

• Sharps Waste generated at sites include all contaminated needles,

specimen/sample tubes/glass/plastic, slides, plastic pipettes, units attached to needles, soft sharps from platelet sets.

• Compass waste collects the full sealed containers from the Waste Storage area at SANBS, Pinetown Campus.

• The waste is transported by Compass Waste and it is autoclaved at Compass

Waste Facility, Westmead, Durban. Infectious waste

• Includes used gloves, plasters, cotton swabs, lab coats, etc.

• This is dispose of into Red Wheelie Bins.

• Compass Waste collects the waste and it is autoclaved at Compass Waste

Facility, Westmead, Durban. Anatomical Waste:

• Anatomical Waste includes defective blood unites associated blood products and this is incinerated.

• The container used to dispose anatomical waste is a rigid red bucket.

• Compass Waste transport this waste to Gauteng Enviroserv where it is incinerated.

Pharmaceutical Waste:

• Pharmaceutical Waste: includes Expired medicines.

• Pharmaceutical Waste is collected by Compass Waste when there is a full container.

• Pharmaceutical Waste is transported to Gauteng Enviroserv where it is

incinerated. NOTE: Compass Waste use a number of incinerators depending on the

availability.. Optimum in George

Enviroserv in Roodpeoort North West Medical in Klerksdorp

Contact Person:

Petro Doubell Telephone : 031 7924217

Facsimile : 031 7924240 Cell Phone: 0828028649

Email: [email protected] Web: http://www.compass.za.net

Pam Flanagan

National Compliance Manager Tel: 031 700 5655

Cell: 071 680 9235 Fax: 086 573 9250

Email: [email protected]

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Appendix D: Recent Waste Disposal Certificates

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Compass Waste Services

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Wasteman

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Appendix E: Valid Trade Effluent Permit

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Appendix F: CP-TRA-002.0 Transportation Safety Procedures

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Appendix G: SOP-TRA-001.0 Dispatching Products and Goods

using a Courier Waybill

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Appendix H:SOP-HSE-003 Safety, Health and Environment

Incident Management

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Appendix I: Environmental awareness do’s and don’ts summary

sheets

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BASIC RULES OF

CONDUCT The following list represents the basic Do’s and Don’ts towards environmental awareness, which all participants in this project must consider whilst carrying out their tasks. These are not exhaustive and serve as a quick reference aid.

NOTE: ALL new site personnel must attend an environmental awareness presentation. Please inform your foreman or manager if you have not attended such a presentation or contact the SHEQ Co-ordinator.

DO: • USE THE TOILET FACILITIES

PROVIDED – REPORT DIRTY OR FULL FACILITIES.

• CLEAR YOUR WORK AREAS OF LITTER AND BUILDING RUBBISH AT THE END OF EACH DAY – use the waste bins provided and ensure that litter will not blow away.

• REPORT ALL FUEL OR OIL SPILLS IMMEDIATELY & STOP THE SPILL CONTINUING.

• DISPOSE OF CIGARETTES AND MATCHES CAREFULLY. (Littering is an offence.)

• CONFINE WORK AND STORAGE OF EQUIPMENT TO WITHIN THE IMMEDIATE WORK AREA.

• USE ALL SAFETY EQUIPMENT AND COMPLY WITH ALL SAFETY PROCEDURES.

• PREVENT CONTAMINATION OR POLLUTION OF STREAMS AND WATER CHANNELS.

• ENSURE A WORKING FIRE EXTINGUISHER IS IMMEDIATELY AT HAND IF ANY ‘HOT WORK’ IS UNDERTAKEN e.g. welding, grinding, gas cutting, etc.

• REPORT ANY INJURY OF AN ANIMAL. • DRIVE ON DESIGNATED ROUTES

ONLY. • PREVENT EXCESSIVE DUST AND

NOISE.

DO NOT:

• REMOVE OR DAMAGE VEGETATION WITHOUT DIRECT INSTRUCTION.

• MAKE ANY FIRES. • INJURE, TRAP, FEED OR HARM ANY

ANIMALS – this includes birds, frogs, snakes, lizards, etc.

• ENTER ANY FENCED OFF OR MARKED AREA.

• ALLOW CEMENT OR CEMENT BAGS TO BLOW AROUND.

• SPEED OR DRIVE RECKLESSLY • ALLOW WASTE, LITTER, OILS OR

FOREIGN MATERIALS INTO THE STREAM.

• SWIM IN THE DAM. • LITTER OR LEAVE FOOD LYING

AROUND. Notes: 1. Should any animals such as tortoises,

chameleons or snakes be encountered then do not harm them. The SHEQ Co-ordinator or RE should be contacted to remove these safely. The harming of any animal will result in disciplinary action.

2. Construction and heavy machine operators must be particularly sensitive to staying within access routes and prevention of unnecessary damage. Dust and noise is also of particular concern. Ensure that vehicles and machinery do not leak fuel or oils. Refuelling or maintenance must be done within the maintenance camp area only.

3. Alien plant clearing and control work teams must be closely supervised.

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BASIESE GEDRAGSKODES Die volgende lys verteenwoordig die Moets en Moenies vir omgewingsbewustheid wat alle deelnemers aan hierdie projek in ag moet neem tydens die uitvoer van hul take. Hierdie lys is nie volledig nie en dien slegs as ‘n vinnige verwysing. NOTA: ALLE nuwe terreinpersoneel moet ‘n aanbieding ten opsigte van omgewingsbewustheid bywoon. Indien u nog nie so ‘n aanbieding bygewoon het nie, lig asseblief u voorman of bestuurder in of kontak die Omgewings Terreinbeampte.

MOETS: GEBRUIK DIE BESKIKBARE TOILET-GERIEWE – RAPPORTEER VUIL OF VOL GERIEWE. • MAAK U WERKPLEK SKOON VAN

ROMMEL OF BOUROMMEL AAN DIE EINDE VAN ELKE DAG – gebruik beskikbare vullisdromme en verseker dat rommel nie rondwaai nie.

• RAPPORTEER ALLE BRANDSTOF- EN OLIE STORTINGS ONMIDDELLIK – STOP VERDERE STORTING.

• WEES VERSIGTIG MET DIE WEGDOEN VAN SIGARETTE EN VUURHOUTJIES. (Rommelstrooi is ‘n oortreding.)

• BEPERK WERKAKTIWITEITE EN DIE STOOR VAN TOERUSTING TOT DIE ONMIDDELLIKE WERKAREA.

• GEBRUIK VEILIGHEIDSTOERUSTING EN VOLDOEN AAN ALLE VEILIGHEIDS-MAATREËLS.

• VOORKOM BESOEDELING VAN STROME EN WATERWEË.

• VERSEKER DAT ‘N BRANDBLUSSER IN WERKENDE TOESTAND BYDERHAND IS WANNEER ‘WARM WERK’ VERRIG WORD bv. Sweis, wegslyp, gassny, ens.

• RAPPORTEER BESEERDE DIERE. • RY SLEGS OP AANGEWESE ROETES. • VOORKOM OORMATIGE STOF EN

GERAAS.

MOENIE:

• PLANTEGROEI VERWYDER OF BESKADIG SONDER DIREKTE INSTRUKSIE NIE.

• ENIGE VURE MAAK NIE. • ENIGE DIERE DOODMAAK, BESEER,

VANG OF VOER NIE, insluitende voëls, paddas, slange, akkedisse, ens.

• ENIGE OMHEINDE OF AFGESPERDE AREAS BETREE NIE.

• SEMENT OF SEMENTSAKKE LAAT RONDWAAI NIE.

• VINNIG OF ROEKELOOS BESTUUR NIE. • ENIGE ROMMEL, AFVAL, OLIE OF

ENIGE VREEMDE MATERIAAL IN STROME LAAT BELAND NIE.

• IN DIE DAM SWEM NIE. • ROMMELSTROOI OF KOS LAAT

RONDLÊ NIE. Notas: 1. Indien enige diere soos skilpaaie,

verkleurmannetjies of slange teëgekom word, moet hulle nie beseer of doodmaak nie. Kontak die OTB of RI om hulle veilig te verwyder. Die besering van diere sal lei tot dissiplinêre optrede.

2. Operateurs van konstruksie- en swaar masjiene moet veral versigtig wees om binne toegangsroetes te bly en om enige onnodige skade te voorkom. Verseker dat voertuie en masjiene nie olie of brandstof lek nie. Brandstofaanvulling en voertuigonderhoud mag slegs binne die onderhoudsarea gedoen word.

3. Streng toesig moet gehou word oor indringerplantbeheerspanne.

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EZIPPHAMBILI

EKUNYANZELEKILEYO

UKUBA ZENZIWE

Zonke ezi zinto zilandelayo zizinto ekufuneka zenziwe nekufuneka zingenziwanga. Wonke umntu ofikayo kufuncka afundiswe ngemigaqo kupala. Needa yazisa iforman yakho ikuba awukhange uye kufundiswa.

IZINTO EMAZENZIWE • SEBENZISA IZINDLU ZANGASESE, YAZISA

XA KUKHO UMONAKALO. • ZAMA UKUCOCA APHO UBUSEBENZA

KHONA. • SEBENZISA IMIGQOMO YENKUKUMA

UNGAYEKI IPHAPHTIEKE. • YAZISA XA UBONA IOIL ECHITHSKALAYO

OKANYE IPETROL. • CIMA LOZOLI CIGARETTE XA U

• GQIBIBILE UKUTSHAYA • ZONKE IZIXHOBO USEBENZA ZIBUYISELE

APHO ZIHLAKA KHONA XA UCGIBILE APHO ZIHLALA KHONA XA UGQIBILE UKUZISEBENZISA.

• ZISEBENZISE IZIKHUSELIXA UZINKIWE. • SUKUGALELA IZINTO EMLANJENI. • MASIBEKHO ISICIMA MLILO XAUSEBENZA

NGOMLILO. • YAZISA MSINYANE XA UBONE

ISILWANYANA EZONZAKELEYO. • XAUQHUBA ISITHUTHI HAMBA

ENDLELENI QHA UNGAFATHULINJE. • NAPHINA ZAMAUNGENZI THULI OKANYE

INGXOLO XA USEBENZA.

EMAZINGENZIWA • SUKUSUSA NESIPHINA ISITYALO

UNGAKHANGE UXELELWE • SUKWENZA MLILO NOKUBA SEKUBANDA • AMAGQARA UKUBULALA IZILWANYANA

NOKUZIFIDA AKUVUMELEKANGA • SUKUNGENA XA KUVALIWE NGAPHANDLE

KWE MVUME • INGXOWA ZESAMENTE MAZINCEDWE

ZINGALAHLWA NJE • SUKUQHUBA NGESANTYA

ESIPHAKAMILEYO • SUKUGALELE NAYIPHI INTO PHAYA

EMLANJENI

• SUKUQUBHA EDAMENI Q OQOSHA YONK INKUKUMA

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Appendix J: Environmental method statement template

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ENVIRONMENTAL METHOD STATEMENT Project: Ref. No.: SHEQ Co-ordinator:

Date compiled: Date approved by SHEQ Co-ordinator: Contractor: Signature:

TITLE: What (a brief description of the work to be undertaken)

How (a detailed description of the process of work, methods and materials)

Where (a description/sketch map of the locality of work, if applicable)

When (the sequencing of actions with due commencement dates and completion date estimates) Comments:

Special conditions: