Safety, health and environmental (SHE) performance

Our policy

Omnia is an active member of the Chemical and Allied Industries’ Association (CAIA) and a signatory to the association’s Responsible Care initiative. Committed to continual improvement in all aspects of our health, safety and environmental performance, we strive to align our business with the global Responsible Care® principles, which requires us to:

	Conduct our operations in a manner that minimises adverse environmental impacts and protects the health and safety of our employees and the public.
	Manage the triple bottom line of our operations as an integral part of our business.
	Integrate health, safety and environmental considerations into our planning for new products and processes.
	Use resources efficiently and minimise waste.
	Engage and work with people to understand and address their concerns and expectations.
	Co-operate with governments and organisations in the development and implementation of effective regulations and standards.
	Provide help and advice to foster the responsible management of chemicals by those who manage and use them along the product chain.

To entrench these commitments throughout the Group, we have committed ourselves to implementing an Integrated Management System (IMS), which is based on ISO 9001, ISO 14 001 and OHSAS 18 001 guidelines. The roll-out of the IMS has been completed at Omnia Fertilizer and BME, and is anticipated to be completed at Protea Chemicals by the end of 2011.

In addition to health and safety committees at all sites, a joint Safety, Health, Environment and Quality (SHEQ) committee is in place, chaired by the Group general manager for engineering projects and services. The SHEQ committee meets on a quarterly basis to discuss SHEQ projects and issues of mutual interest within the Group, and to transfer knowledge and best practice between divisions.

SHEQ aspects, impacts and risks per site are continuously evaluated and recorded on the respective registers for all our sites in terms of the IMS. Occupational health and safety risk assessments are also conducted on each site once every two years as per the requirements of the Occupational Health and Safety (OHS) Act.

The results of these assessments are communicated to the health and safety committees of all sites, and remedial projects are identified, implemented and monitored. A summary of major risks is included in the Omnia Group risk management report which is reviewed by the Omnia Group risk committee in its bi-annual meetings.

The Group has also decided to formulate more stringent product requirements for its international suppliers. Checks by qualified Omnia personnel are now standard procedure on internationally supplied materials. These quality measures are applied throughout the supply chain, from the supplier’s facilities to the point of delivery.

Measuring our performance

Several initiatives to continually improve Omnia’s safety, health, and environmental performance, and the quality of Omnia’s products and services, have been implemented during the period under review. Opportunities for improvement still exist following our philosophy of continued improvement and specific projects will be launched in the next financial year to address priority issues.

SHE expenditure

The Group’s total expenditure on safety, health and environmental aspects for the period under review increased from R61 million in F2009 to R77 million in F2010. Capital spend during 2010 included R24 million for a co-generation project, which involved the installation of a 1 920 kW turbo-generator at the Omnia Fertilizer factory in Sasolburg, which was successfully commissioned during the year.

Transport

Transport incidents

The number of transport-related incidents is a cause for concern. Specific measures were implemented for the approval of contractors used for deliveries, vehicle checklists and directives on load securement. The total number of transport incidents decreased from 57 in F2009 to 55 in F2010. All of these incidents have been dealt with in a responsible way and rehabilitation was introduced where required.

Transport incidents include all transport incidents over land, sea, air and rail which involve raw materials, intermediates, final product, own vehicles and contractor vehicles. They exclude claims relating to insurance incidents on employee motor fleet vehicles.

Incidents per ton manufactured

Transport incidents per 100 000 ton of product manufactured increased from 2,81 to 3,02 due to a decrease in the volume of products manufactured and an increase in the amount of products traded.

Legal incidents

The number of legal incidents, which include SHE-related fines, warnings summonses and penalties, increased significantly from two during F2009 to 17 in F2010. At Omnia Fertilizer, the Department of Labour investigated and completed three lost-time injuries in a satisfactory manner. The fourth incident at this division related to a visit from the Department of Environmental Affairs for a compliance audit on a Record of Decision that was issued based on an Environmental Impact Assessment.

At Protea Chemicals Division, six effluent contravention notices were received from the Nelson Mandela Local Municipality for off-specification effluent. Three section S24G administrative fines were also paid. The Ethikwini Municipality issued an effluent contravention notice to Zetachem and KwaZulu-Natal Quality Street, while a complaint relating to dust and effluent at the division’s Springs site was investigated and managed.

Water consumption

The Group’s total water consumption increased from 861 219 kilo litres in F2009 to 1 192 378 kilo litres in F2010, while our water consumption per ton of product increased from 0,357 kilo litres/ton of product during F2009 to 0,436 kilo litres/ ton in F2010. These increases were mainly due to greater water usage at our Sasolburg site because of a decrease in cycles at the nitric acid cooling tower and an increase in production. However, water management changes have been implemented, which significantly optimise our re-use of water and decrease our municipal water use.

Energy consumption

The Group’s total energy consumption decreased from 8 690 113 giga-joules (GJ) in F2009 to 8 100 529 GJ in F2010, while total energy consumption/ton of product manufactured dropped from 3,6 GJ/ton to 3,0 GJ/ton over the same period.

This reduction in energy use can mainly be attributed to optimisation efforts and the implementation of a new generator at our fertilizer plant in Sasolburg, while our Rustenburg fertilizer plant consumed less energy because of lower production volumes.

Zetachem and PFP use HFO boilers, which make the manufacturing process, at PFP in particular, energy intensive, negatively affected Protea Chemicals’ energy use figures. At Zetachem’s hypochlorite plant, membrane damage due to power outages experienced in 2008 is now in evidence, and reflected in higher than normal power consumption per kilogram of hypochlorite.

Waste

General waste to landfill

Due to construction activities at our Sasolburg factory, where building rubble is removed to the local municipality landfill site, the Group’s total volume of general waste disposed of during the period under review increased from 2 050 tons in F2009 to 4 761 tons in F2010.

Hazardous waste to landfill

The total volume of hazardous waste rose during F2010, but disposal was to a registered waste site in accordance with legal requirements. 828 tons was disposed of compared to 686 tons in F2009. Waste removed to landfill sites increased due to the cleaning of acid dams in the Fertilizer division. An improved waste management and classification system, introduced at Protea Chemicals’ East London and Port Elizabeth sites, also contributed to the rise in the disposal of hazardous waste.

Recycled waste

A decrease in the volume of waste recycled – from 5 729 tons in F2009 to 759 tons in F2010 can be attributed to increased internal recycling and reworking of products at Omnia Fertilizer’s Sasolburg site.

Environmental incidents

The Omnia Group experienced a slight increase in the number of environmental incidents, from 92 in F2009 to 94 in F2010, but all have been dealt with according to the NEMA principles. Eight of these incidents – three occurring at our Fertilizer division, four at Protea Chemicals and one incident at BME – can be classified as major incidents.

Major environmental incidents are defined as:

	Incidents involving the release of greater than 1 ton of chemicals/diesel fuel, oxidiser etc be it in the solid, liquid or gaseous form.
	Damage to ecosystems outside of the site/factory (for example, fish, bird or wildlife kills, and damage to flora).
	“Written” notices from government departments demanding action.
	Emergency services involving larger spills/leaks attracting media attention and/or causing visible damage to ecosystems (for example, bird or fish kills, and dead vegetation).
	Major deviations from effluent specifications for long periods of time.

At Omnia Fertilizer, all incidents related to transport, with vehicles being involved in accidents while transporting product to customers. Three of the incidents at Protea Chemicals related to storm water contamination at the Cape Killarney Gardens site and at Nkomati mine. The last incident was reported at the Inlands Springs site where white precipitate emanated from historical pollution due to leaking of the contaminated storm water dam on the site. The incidents were reported to authorities and measures have been taken to reduce the impact. The incident at BME occurred at bulk distribution when a driver had a heart attack while transporting product to a customer.

Environmental initiatives

Air quality

The following initiatives were implemented as part of the Omnia Group’s commitment to continually improve the air quality management within the Group.

Monitoring and reporting of greenhouse gas emissions (GHG)

Omnia acknowledges its responsibility to monitor and report on the emission of greenhouse gases associated with its activities and also to report on its strategy to continually reduce its GHG emissions. Omnia’s approach can be summarised as follows:

	An external consultant was appointed during 2008 to conduct a baseline GHG emissions inventory for the Omnia Group, which consists of Omnia Group Services, Omnia Fertilizer, Protea Chemicals and BME. The GHG gas emissions were calculated for the period 1 April 2006 to 31 March 2007. This baseline inventory is intended to be used as a reference to demonstrate future improvement in terms of the reduction in such emissions. The methodology applied to calculate GHG emissions involved:
	–	ISO14064 Part 1: “Specification with guidance at the organisational level for the quantification and reporting of greenhouse gas emissions and removals“ was used as the basis for the calculation of GHG emissions.
	–	Guidelines provided by the Greenhouse Gas Protocol were also considered during the calculation of the GHG emissions.
	–	Using the ISO 14064-1 (2006) principles and requirements, data was then collected on:
		–	Total purchased electricity.
		–	Energy consumption on manufacturing sites such as diesel, coal and natural gas.
		–	Nitrous oxide emissions due to the production of nitric acid.
		–	Employee business travel, including flight destinations associated with marketing and management.
		–	External distribution logistics.
		–	Use/disposal of company products and services.
		–	Transportation within the company supply chain.
	–	The following emissions from the sites were, in line with the above protocol, considered for purposes of the calculation of GHG emissions:
		–	Direct GHG emissions (scope 1) from the sites, including the combustion of fuel such as coal, natural gas, as well as on-site diesel consumption.
		–	Energy indirect emissions (scope 2), including emissions associated with the production and distribution of electricity from the national grid, which is coal-based.
		–	Other indirect emissions (scope 3), including emissions from all outsourced activities, such as employee business travel, external distribution logistics, use and disposal of company products and services, company supply chain, etc. This is in compliance with the gate to gate principle – defined as an inventory that consists of all activities controllable between the gates of the supplier and the gates of the consumer – and will ensure a complete picture of the baseline GHG footprint. (The diagram included below was obtained from the GHG reporting protocol, and is an overview of scopes and emissions across a value chain.)

The contributions of each of Omnia Group’s divisions towards total GHG emissions can be summarised as follows:

A follow-up GHG emissions survey to calculate and evaluate progress in terms of the reduction of GHG emissions for the financial year April 2009 to March 2010 is scheduled to be completed by the end of July 2010. In addition, a management practice standard, which serves as a guideline for the monitoring and reporting of GHG, was recently developed by the CAIA as part of its Responsible Care Initiative®. We will use this management practice standard as a guideline to calculate and report on GHGs in future.

The Executive Board of the Clean Development Mechanism Protocol issued some 504 795 assurances in terms of our Certified Emission Reductions (CERs) from February 2008 to date for the successful operation of Omnia’s EnviNox® plant, which was implemented during February 2008. The objective of this project is to reduce the NOx and N2O emissions from the nitric acid plant at Omnia Fertilizer in Sasolburg. Nitrogen oxide (NOx) emissions are regulated in terms of the Atmospheric Pollution Prevention Act (73 of 1965), but N2O emissions are not currently regulated. N2O is classified as a GHG with a Global Warming Potential (GWP) estimated to be 310 times greater than that of CO2. GHG emissions, including N2O, is believed to contribute towards global climate change. Omnia identified the reduction of NOx and N2O emissions from its nitric acid plant as an opportunity to contribute towards the improvement of the air quality of the Vaal Triangle, which is a declared National Priority Area in terms of the National Environmental Management Air Quality Act (Act 39 of 2004).

Air quality permits and compliance

	Existing Air Quality Certificates in terms of the Atmospheric Pollution Prevention Act (45 of 1965) were reviewed and updated, and are being converted to the new format required in terms of the National Environmental Management Air Quality Act. The reviewed permit applications were submitted to the National Department of Environmental Aff airs for approval and issuing of new permits in terms of the National Environmental Management Air Quality Act.
	Protea Specialities Chemicals has purchased equipment to monitor exhaust emissions from its vehicles. The equipment will be used to monitor the legal compliance of emissions from all of its vehicles on a three-monthly basis.
	Omnia Fertilizer has launched an Air Quality Compliance project to confirm existing emissions and determine mitigation measures that may be required to comply with the new limits.

Water, waste and effluent management

	At Omnia Fertilizer, a new Safety, Health and Environmental Manager, who is also a specialist in water quality management, has been appointed. The new manager’s crucial tasks include reviewing and improving water quality management on all sites within Omnia Fertilizer. Projects commissioned to improve water quality management within Omnia Fertilizer can be summarised as follows:
	–	A project to improve water management at the Sasolburg site has been commissioned as part of the Integrated Water Use Licence Application (IWULA) submitted to the Department of Water Affairs. The following important initiatives are included in this project:
		–	Development of a storm water management plan and the installation of infrastructure to separate storm water run-off from potentially contaminated and clean areas. The capacity of the existing storm water effluent dams in Sasolburg was also increased at an estimated cost of R8 million.
		–	An investigation into alternatives to improve the quality of cooling water flows down from the nitric acid plant’s existing cooling towers.
		–	A project to update and improve the water balance for the Sasolburg factory.
		–	Upgrading the water management systems for each of the production units at the Sasolburg factory.
		–	Reduction in water use through optimisation of the use of the cooling towers on the site.
		–	Assessment and optimisation of the waste and effluent management practices at the Sasolburg factory.
		–	An Integrated Water and Waste Management Plan (IWWMP) has been submitted.
	–	The Integrated Water Use Licence Application and Integrated Water and Waste Management Plan for Rustenburg has been drafted, but needs to be revised to include the mothballing alternative. The following important initiatives are included in this project:
		–	Development of a storm water management plan for the site and the upgrade of existing infrastructure on the site.
		–	An investigation to refine and improve the water balance for the site.
		–	Alternative water management practices.
		–	Assessing of waste and effluent management practices on site.
	Protea Chemicals’ initiatives to improve water, effluent and waste management can be summarised as follows:
	–	A number of areas at Protea Chemicals Inland’s Wadeville site were identified to be hard-surfaced to prevent soil and ground water pollution. The hard surfacing of all of these areas will require substantial capital investment and will therefore be phased in according to priority over the next five years.
	–	A project to improve the hard surfacing at Protea Chemicals Inland’s site in Springs has been completed.
	–	The establishment and implementation of ground water monitoring programmes at all Protea Chemicals facilities are current priority areas.