Information
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Areas inspected
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Buisness
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Department
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Review Period
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Manager
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Conducted on
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Prepared by
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Inspection team
Scope and/or intent of the standard
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This standard is applicable to all business units and managed operations; and all phases of their lifecycle from exploration through post closure. It defines the minimum acceptable requirements for behaviours and/or conditions in respect of managing hazardous materials and non-mineral wastes, which, if not met, could materially impact the Group. It covers the important storage, use and ultimate disposal of hydrocarbons, reagents, process fluids, non-mineral wastes and other materials which could pose environmental risks because of their physical and chemical properties.
Control requirements
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Specific management requirements in this performance standard apply in addition to any
general requirements defined in the Management System standard.
Other relevant documents:
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• Management system standard
• Hazardous materials and non-mineral waste control minimisation guidance
• Chemically reactive mineral waste control standard guidance
• Land disturbance control and rehabilitation standard guidance
• Closure guideline
• Product stewardship guidance
• H1 Chemicals and hazardous substances exposure control standard
• Hazardous substances occupational health standards and associated guidance
• Occupational exposure limits health standards and associated guidance
• Annual Social and Environment (S&E) survey guideline
E15 – Hazardous materials and non-mineral waste control and minimisation
2. Planning
Clause number 2.1
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The level of effort required to meet subsequent clauses in this standard is determined by materiality thresholds, described in guidance to this standard.
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Additional information on the intent/interpretation of the clause
The purpose of this clause is to define a level of risk for hazardous materials and non-mineral waste impacts that the business has determined to be as low as reasonably practical (ALARP). Refer to the Materiality Thresholds for Hazardous Materials and Non-mineral Waste Control and Minimisation to determine whether or not a business is classified as “above threshold” or “below threshold” and evaluate accordingly.
Parameter Threshold
Hazardous waste generation 2 tpy
Non-hazardous waste generation 200 tpy
Cumulative onsite hazardous waste 20 t (cumulative)
Cumulative onsite non-hazardous waste 2,000 t (cumulative)
Different hazard characteristics and quantities of non-mineral wastes trigger different legal requirements and management techniques. Therefore waste types and quantities for above threshold businesses drive different levels of effort to meet the subsequent clauses of this standard. -
Evaluation steps
[O] Conduct an orientation tour of the business and surrounding area with the intent of gaining a basic understanding of how hazardous materials and non-mineral waste is managed.
[I] Ask the designated representative from the business if the business has identified what risks are posed to the environment by hazardous materials and non-mineral wastes.
[I] Ask the designated representative from the business about current practice for identifying, characterizing and evaluating hazardous material and non-mineral waste impacts.
[D] Ask to see the established risk identification and management process for identifying risks related to hazardous materials and non-mineral waste management. Ask what the qualifications are of the individuals participating in the risk assessment.
[D] Review the operations environmental risk register for hazardous material and non-mineral waste related risks. Risks classified as Level III or greater require additional follow up such as a review of risk mitigation plans with assigned accountable parties and evidence of risk reduction progress tracking. -
Repeat Finding
Clause number 2.2
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Identify and characterise all hazardous materials and non-mineral wastes imported, generated, exported, stored or disposed. Maintain an inventory of the locations, volumes and contents of bulk hazardous materials storage facilities. Maintain a documented annual and cumulative inventory of all non-mineral waste materials disposed on-site or sent off site.
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Additional information on the intent/interpretation of the clause:
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Evaluation steps
[I] Ask the designated business representative how the business characterises all hazardous materials and non-mineral wastes imported, generated, exported or disposed.
[D] Obtain and review a copy of the business’ hazardous materials inventory. Determine whether the inventory includes all potential locations, volumes and contents of bulk hazardous material storage.
[O] Conduct filed observations of a sample storage locations listed on inventory to determine if the inventory is adequate and accurate.
[I] Ask the designated business representative if the business maintains a documented inventory of all non-mineral waste materials disposed on-site or sent off site.
[D] Obtain and review a copy of the business’ non-mineral waste inventory. Determine if the inventory is updated annually and includes cumulative totals.
[O] Conduct filed observations of a sample of non-mineral waste storage locations to determine if the inventory is adequate and accurate. -
Repeat Finding
Clause number 2.3
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Develop and maintain a register which documents the location, scale, characteristics, environmental risks and legal liabilities associated with contaminated and potentially contaminates sites.
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Additional information on the intent/interpretation of the clause:
Requirements for businesses above or below threshold levels are similar for contaminated sites. -
Evaluation steps
[I] Ask the designated business representative if the business maintains a register of contaminated and potentially contaminated sites.
[D] Obtain and review a copy of the business’ contaminated/potentially contaminated sites register. Determine whether the register includes the location, scale, characteristics, environmental risks and legal liabilities associated with contaminated and potentially contaminated sites.
[I] Ask the designated business representative about the process the business used to develop and maintain the register and whether the business is required to maintain specific documentation to comply with legal or regulatory requirements. -
Repeat Finding
Clause number 2.4
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Characterise soil and water contamination on lands managed by the business or for which the business may have responsibility for all known or potentially contaminated sites.
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Additional information on the intent/interpretation of the clause:
Requirements for businesses above or below threshold levels are similar for contaminated sites. -
Evaluation steps
[I] Ask the designated business representative if the business has characterised known or potential soil and water contamination on lands the business manages or may have responsibility for.
[D] Obtain and review characterisation documentation such as environmental impact assessments, geophysical information, sampling of soils, sediments, surface and ground water, modelling outputs, etc.
[O] Conduct field observations with the intent on finding evidence of historic or current contamination. Determine whether what is evident in the field has been characterised accurately. -
Repeat Finding
Clause number 2.5
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Assess the impacts and risks posed by potential hazardous material release to human health, environment, biodiversity and ecosystem services and use this information to inform the design of containment infrastructure, monitoring and management strategies.
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Additional information on the intent/interpretation of the clause:
The level of containment infrastructure, monitoring and management should be commensurate with the level of impact and or risk of release. -
Evaluation steps
[D] Obtain and review the operation’s environmental risk register to determine whether impacts and risks posed by potential hazardous material release have been assess with regard to human health, environment, biodiversity and ecosystem services.
[I] Ask the designated business representative if risk and impact information was/is used to design containment infrastructure, monitoring and management strategies.
[O] Conduct field inspections to determine whether the site has implemented adequate containment, monitoring and management strategies for all hazardous material stored on site to prevent release.
[I] Ask the designated business representative whether the site has had any recent hazardous material releases. Review documentation associated with the release to determine whether corrective actions have been implemented to ensure containment, monitoring and management strategies are adequate to prevent future releases. -
Repeat Finding
2. Implementation and operation
Clause number 2.6
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Design and maintain secondary containment for all tanks, drum and bulk storage areas containing hazardous materials, as well as transfer facilities with a higher risk of spills that is capable of safely holding the maximum credible release.
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Additional information on the intent/interpretation of the clause:
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Evaluation steps
[I] Ask the designated business representative if the business has designed and maintained secondary containment for all tanks, drums, bulk storage and transfer areas containing hazardous materials capable of safely holding the maximum credible release.
[I] Ask the designated business representative how a maximum credible release is determined. (In the absence of regulation, the containment must hold 110% of the material stored in the containment).
[O] Conduct field observations to determine whether containment is sufficient and if the proximity to receiving environments has been considered. -
Repeat Finding
Clause number 2.7
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Store waste materials in the correct type of container.
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Additional information on the intent/interpretation of the clause:
Container storage and management should be evaluated in the same manner regardless of threshold. -
Evaluation steps
[D] Obtain and review documentation of the operation’s hazardous material waste management program.
[I] Ask the designated business representative if the business must comply with regulation dictating hazardous material and waste management.
[I] Ask the designated business representative how the business determines the type of container to store waste materials in.
[O] Conduct field observations to determine whether or not waste materials are being labelled and stored in appropriate containers and designated locations. -
Repeat Finding
Clause number 2.8
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Maintain spill response equipment, systems and teams to ensure hazardous material releases are promptly controlled, contained and remediated.
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Additional information on the intent/interpretation of the clause:
Spill response and control procedures should be scaled to the size of the operation, the type of waste on site, and proximity/availability of local emergency response centers. -
Evaluation steps
[D] Obtain and review a copy of the business’ spill response and control procedures.
[I] Ask the designated business representative how the spill response and control procedures were developed.
[O] Conduct field observations to determine if the level of spill response and control preparedness is appropriate for the level of risk posed by a potential release. -
Repeat Finding
Clause number 2.9
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Construct new storage tanks and pipelines containing or transporting hazardous materials above ground, unless a documented risk assessment demonstrates a lower risk for underground installation.
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Additional information on the intent/interpretation of the clause:
Construction of storage tanks and pipelines should be audited with the same rigor regardless of threshold. -
Evaluation steps
[I] Ask the designated business representative if the business has any storage tanks and/or pipelines containing or transporting hazardous materials underground.
[D] Obtain and review a documented risk assessment for all underground storage and transport of hazardous materials. Ensure that the Managing Director has authorised the risk assessment. -
Repeat Finding
Clause number 2.10
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Incorporate additional controls, such as secondary containment, inventory monitoring and leak detection systems, for any new and existing underground tanks and pipelines. Underground tanks and pipelines must be authorised by the businesses managing director.
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Additional information on the intent/interpretation of the clause:
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Evaluation steps
[I] Ask the designated business representative to articulate the level of control, monitoring and leak detection the business has in place for all underground tanks and pipelines.
[D] Obtain and review a copy of the business’ monitoring and leak detection records for all underground tanks and pipelines.
[I] Ask the designated business representative to articulate the business’ response if a leak is detected. Ask if there has been any recent uncontrolled releases from underground tanks or pipelines.
[O] Conduct field observations to determine whether or not the level of control is commensurate with the level of risk posed by a release. -
Repeat Finding
Clause number 2.11
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Dispose non-mineral waste, whether onsite or offsite, in permanent engineered, controlled and approved facilities that are designed and operated in accordance with local laws and regulations or internal performance criteria.
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Additional information on the intent/interpretation of the clause:
Disposal requirements for non-mineral wastes should be the same at all thresholds. -
Evaluation steps
[D] Obtain and review a copy of recent waste disposal records.
[I] Ask if the operation maintains an inventory, including location, for all wastes stored on-site and sent off-site.
[I] Ask the designated business representative if the site’s non-mineral waste storage areas are designed and operated in accordance with local laws and regulations. If there are no local laws and/or regulations that business must comply with ask for the business’ internal performance criteria.
[I] Ask how internal performance criteria are set and authorized.
[D] Obtain and review design and operation documentation for onsite and offsite disposal facilities. Determine whether design and operation criteria are being met. -
Repeat Finding
Clause number 2.12
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Design and verify that landfill liners, covers and leachate management systems meet compliance criteria and avoid the creation of environmental liabilities, consistent with the hazards posed by the contained waste and the sensitivity of the receiving environment.
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Additional information on the intent/interpretation of the clause:
Design requirements at landfills should be the same at all thresholds. -
Evaluation steps
[I] Ask the designated business representative if/how the business has verified that landfill liners, covers and leachate management systems meet compliance criteria.
[I] Ask how compliance criteria are determined.
[D] Obtain and review operating procedures and compliance documentation, such as monitoring programs and procedures, waste storage facility design specifications, inspection reports, etc.
[O] Conduct field observations to determine whether compliance criteria are being met, that facilities have been designed in such a way to avoid the creation of environmental liabilities, consistent with the hazards posed by the contained waste and the sensitivity of the receiving environment. -
Repeat Finding
Clause number 2.13
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Consider and document hazardous material, contaminated sites, and non-mineral waste risks and impacts, including opportunities to avoid or reduce waste generation and waste impacts, prior to implementing a change.
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Additional information on the intent/interpretation of the clause:
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Evaluation steps
[I] Ask how the operation considers and documents hazardous material, contaminated sites, and non-mineral risks and impacts during management of change.
[D] Obtain and review documentation of the operation’s management of change programme, determine whether the programme requires consideration of non-mineral waste risks, including opportunities to avoid or reduce waste generation and waste impacts prior to implementing a change.
[D] Review a recent change involving non-mineral waste and/or a non-mineral waste storage site to determine whether or not the site’s management of change process was followed and whether opportunities to avoid or reduce waste generation and waste impacts were considered prior to implementing the change. -
Repeat Finding
Clause number 2.14
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Consider and document hazardous materials, contaminated sites and non-mineral waste risks and impacts as part of the technical and financial evaluation of capital projects.
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Additional information on the intent/interpretation of the clause:
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Evaluation steps
[I] Ask how the operation considers and documents hazardous materials, contaminated sites and non-mineral waste and impacts as part of the evaluation of capital projects.
[D] Obtain and review a sample of the operation’s capital project evaluation documentation and determine whether there has been a specific assessment of hazardous materials, contaminated sites and non-mineral waste risks and impacts. For operations below threshold, a simple and conservative evaluation to confirm that non-mineral waste risks are unlikely to have a substantial impact on project economics is sufficient. For above threshold, operations hazardous materials and waste minimization must be adequately assessed and costed consistent with study guidelines and included in project financial estimates. The level of effort should be commensurate with the impact. -
Repeat Finding
2. Monitoring
Clause number 2.15
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Perform routine inspections of hazardous material and non-mineral waste storage and disposal areas.
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Additional information on the intent/interpretation of the clause:
Inspection of hazardous material and non-mineral waste storage areas should be the same at all thresholds. -
Evaluation steps
[I] Ask the designated business representative if the operation has an inspection program for all hazardous material and non-mineral waste storage and disposal areas.
[D] Obtain and review documentation of the operation’s inspection program.
[I] Ask the designated business representative to explain the basis for the inspection program and if the program has specific performance criteria.
[D] Determine whether inspection criteria are being met.
[O] Conduct field observations, determine whether there is adequate segregation, containment and disposal practices.
[D] Obtain and review certification and licence documentation for all waste vendors. -
Repeat Finding
Clause number 2.16
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Conduct integrity testing of storage tanks and pipelines that store or convey hazardous materials, and monitor waste stored in containers to prevent spills or leakage.
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Additional information on the intent/interpretation of the clause:
Integrity testing of storage tanks and pipelines should be the same at all thresholds. -
Evaluation steps
[D] Obtain and review documentation of the operation’s integrity testing program for storage tanks and pipelines that convey hazardous materials.
[I] Ask the operation the basis for the integrity testing program and associated performance criteria.
[D]Evaluate if performance criteria are being met.
[D] Obtain and review recent integrity testing results. If corrective action was triggered follow up to determine actions have been addressed.
[I] Ask if the operation monitors waste stored in containers to prevent spills and leakage.
[D] Obtain and review monitoring program documentation.
[D] Review recent monitoring records to ensure program is sufficient to prevent spills and leakage. -
Repeat Finding
2. Performance assessment and auditing
Clause number 2.17
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Perform verification assessments of contractors who transport or recycle waste materials, and facilities used for treatment, storage and disposal to confirm that the wastes are being managed appropriately.
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Additional information on the intent/interpretation of the clause:
Verification assessments should be the same at all thresholds. -
Evaluation steps
[I] Ask the designated business representative if the business performs verification assessments of contractors who transport or recycle waste materials and facilities used for treatment, storage and disposal to confirm that wastes are being managed appropriately.
[D]Obtain and review verification assessment procedures and recent documentation. Determine whether wastes being sent off site are being managed appropriately.
[I] Ask the designated business representative what selection criteria and control procedures are used when selecting a third party for transportation, purchase and other recipients of hazardous materials.
[D] Obtain and review documentation of the operation’s use of selection criteria for third party handlers of hazardous materials. Determine if selection criteria is sufficient based on the level of risk introduced and if the criteria is adhered to.
[I] Ask how the business follow’s up on any hazardous material sent off the premises.
[D] Obtain and review follow up documentation such as completed manifests. -
Repeat Finding
Summary of actions
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Are actions required to be raised?
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Action number and description
Inspection action
Sign offs
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Area owner representative
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Environmental representative / Auditor
Summary
