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					Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________




 INTERNATIONAL CYANIDE
 MANAGEMENT INSTITUTE


      Transportation Summary
     Recertification Audit Report

        SASOL Infrachem SiLog

        7th – 11th September 2009



                    For the
    International Cyanide Management Code


________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 1 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________

Name of Operation:                          SiLog Transportation

Name of Operation Owner:                    Sasol Infrachem

Name of Operation Operator:                 SiLog Transportation

Name of Responsible Manager:                Mr Gert Basson

Address:                                    1 Klasie Havenga Avenue,
                                            Sasolburg,
                                            Free State, 1947

Country:                                    South Africa

Telephone:                                  +027 920 3165

Fax:                                        +027 620 3040

E-Mail:                                     gert.basson@sasol.com


Location detail and description of operation:
SiLog Transportation is located on the industrial sites of Sasolburg, off Bergius Street,
known as the “Sasol Midland Site”, near Sasolburg.

The operation provides for the delivery of dangerous chemicals produced at the Sasol
Midland site in product dedicated bulk road tankers. Drivers performing chemical
deliveries are trained and certified competent in knowledge and handling o the respective
dangerous chemicals, including cyanide solution, caustic soda, hydrochloric and CP acids
and Hypo soda.




________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 2 of 9
SasolInfrachemSilog                  TRANSPORTATION
                                                  SUMMARYAUDIT REPORT
7s -l lfr September
                  2009                                 EagleEnvironmental


                                      Auditor's Finding


This operation
             is

        X in full compliance
        n in substantial        *(seebelow)
                       compliance
        n not in compliance

with the International
                     CyanideManagement
                                    Code.
* For cyanidetransportation        seeking
                          operations      Codecertification, Corrective
                                                           the          Action Planto
                  in
  bringan operation substantial          into
                              compliance full compliance   mustbe enclosed with this
  Summary  Audit Report. planmustbe fully implemented
                       The                             within oneyearof the dateof this
  audit.

Audit Company:
             EagleEnvironmental               Audit Team Leader: Arend Hoogervorst

E-mail : arend@eagleenv. za
                      co.

Namesand Signatureof TransportationAuditor:

                                   '%ea^,                                       z/t,/rcto.
Name Lynton Brown                       Signature                       Date


I attest that I meet the criteria for knowledge, experience and conflict of interest for Code
Verification Audit Team Leader, establishedby the International Cyanide ManagementInstitute
and that all membersof the audit team meet the applicablecriteria establishedby the International
Cyanide ManagementInstitute for Code Verification Auditors.

I attestthat this SummaryAudit Reportaccurately              the
                                                   describes findings of the verification audit.
I funher attest that the verification audit was conducted in a professional manner in accordance
with the International Cyanide Management Code Verification Protocol for Cyanide
Transportation Operations and using standard and accepted practices for healttr, safety and
environmentalaudits.



Signed                                                                rf,f*,"
                Arend,[L*,                      LeadAuditor          Date




SasolInfrachemSlLog                Signature
                                               IAuditor                          Januarv2010
                                        Page3 of9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
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7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________

1. TRANSPORT:                     Transport cyanide in a manner that minimizes the
                                  potential for accidents and releases.

Transport Practice 1.1: Select cyanide transport routes to minimize the potential for
                         accidents and releases.

                         X in full compliance

The operation is         �� in substantial compliance                with Transport Practice 1.1

                         �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
A catalogue of 65 route risk assessments were sampled by the auditors. Routes are carefully
selected, risk assessed and checked, kilometre by kilometre (these assessments are initially made
available to the satellite tracking companies to assist in vehicle tracking and monitoring), with
significant route characteristics being briefed to the drivers in the form of notes on the trip sheet.
Risk assessments include consideration of population, infrastructure, geographical and
topographical information, road characteristics and condition, and presence of water and water
courses. Whilst not used on every trip, escorts are used on some identified routes deemed by the
risk assessments to require them.
Meetings were held with local authorities and traffic authorities to discuss options and get
additional advice on route preferences. "Road shows" were organised to discuss transportation
issues along routes. Advance meetings with local authorities, traffic authorities, hospitals, local
councillors, representatives of local communities, taxi associations etc. were arranged to promote
debate and discussion.
Since liaison/linkage with authorities and emergency responders started, Sasol has trained over
5,000 officials and professionals in approaching and safe handling in cyanide emergencies.
Risk assessments are reviewed regularly in addition to reviews that are triggered by condition
reporting. Drivers contribute to maintaining up-to-date information by reporting any changes in
conditions, circumstances or risk after each trip on the manifest and/or the driver complaints
form. Where appropriate, there is further liaison with customers on local conditions and
circumstances (for example, in the case of bad weather influences), before the load sets out. The
transportation auditor physically checked risk assessments against actual road conditions on four
tanker routes.


Transport Practice 1.2: Ensure that personnel operating cyanide handling and transport
                          equipment can perform their jobs with minimum risk to
                          communities and the environment.

                         X in full compliance with

The operation is         �� in substantial compliance                with Transport Practice 1.2

                         �� not in compliance with

________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 4 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________

Summarize the basis for this Finding/Deficiencies Identified:
Before employment, drivers go through a selection process which includes license
checks, driving records, qualifications and psychometric testing. The trainee driver then
goes through a theoretical and practical training programme. Drivers are fully trained in
topics which include theoretical, Standard Heavy Duty Driver training. Initial training
includes working with experienced drivers and extensively tested by both an experienced
driver and the Training Officer before being passed out as competent.
The trainee driver must undertake at least 3 supervised off-loadings each for pump and
pneumatic offloading before he is reviewed by the training practitioner. He is then
assessed and declared competent. Cyanide specific training includes PPE, Legislation,
Emergency Procedures, Tanker Equipment/knowledge, Principles of Off-loading, Fire
Training. Hazmat, and Cyanide First Aid. This training is reinforced by regular refresher
training.


Transport Practice 1.3: Ensure that transport equipment is suitable for the cyanide
                         shipment.

                       X in full compliance with

The operation is       �� in substantial compliance           with Transport Practice 1.3

                       �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
Dedicated cyanide tankers are used which are manufactured and maintained according to
SABS (South African Bureau of Standards) Code 1518 - Design requirements for
dangerous goods vehicles. All tankers go over a weighbridge to check vehicle loads and
the weighbridge is programmed to not print the weighbridge ticket if the load is above the
legal ticket limit. Loading booms at dedicated cyanide loading points have probes fitted
which ensure that tankers are not loaded beyond a designated point.


Transport Practice 1.4: Develop and implement a safety program for transport of
                        cyanide.

                       X in full compliance with

The operation is       �� in substantial compliance           with Transport Practice 1.4

                       �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
The SiLog cyanide tanker fleet number has a cyanide prefix (e.g. A9XX). The vehicle signage
format is dictated by the South African Road Traffic Act and SABS/SANS Codes of Practice and
________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 5 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________
meets UN standards. Three checklists are used to check that vehicles and loads are safe :- (1)
Driver, Vehicle, PPE & Tools Inspection List, (2) Road Vehicle Checklist (Ad Hoc Tractor &
Tanker) and (3) Cyanide Road Vehicle Clearance Certificate. The safety program includes the use
of Training Manuals covering legislation, Offloading, cyanide first aid, and dangerous goods
certificate training. Systems are in place to ensure proper preventative maintenance of equipment.
An independent tracking system checks vehicle progress against plan and notifies of any
variances (e.g. longer driving hours, route deviation, extended stopping). SiLog applies the Sasol
Group-wide alcohol and drug abuse prevention and testing program which includes random
testing and regular medicals.
All documents are covered by a document retention procedure and Delivery documents (POD-
Proof of Delivery), Trip sheets, Planning sheets, Vehicle Inspection Sheets, and Weighbridge
tickets are retained for 5 years. Driver Medical records are retained for 40 years from exit from
company.


Transport Practice 1.5: Follow international standards for transportation of cyanide by
                          sea and air.

                        �� in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 1.5

                        �� not in compliance with

                        X Not applicable


Summarize the basis for this Finding/Deficiencies Identified:
This section is not applicable as no modes of air or sea transport are used but
international standards are used for road transport.


Transport Practice 1.6: Track cyanide shipments to prevent losses during transport.

                        X in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 1.6

                        �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
All drivers carry vehicle mounted cell phones and in cases where there are known route
communications blackouts, drivers adhere to a pre-designated, alternate phone-in plan. All
shipments are tracked using a cellular system by an independent tracking company (Altech). The
Shipment Planner submits a list of deliveries the day before and the tracking company monitors
journeys and checks any deviations from route or route plan with the driver and the vehicle and
shipments controller. Cell phones are checked on ad hoc driver checklist - 2 -3 times per week

________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 6 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________
and recorded on a monthly Communication Check Sheet. Vehicle tracking system tests are
carried out daily with the drivers and communicated to the vehicle and shipments controller.
The vehicle carries a Tremcard, trip sheet, delivery document, and weighbridge ticket. The South
African legal requirement is that the Tremcard must be available in the vehicle "dedicated space"
(South African legal specification) and the customer must have a copy of the MSDS. All vehicles
have a document box and MSDS’s (which are also available in the SiLog control room).


2. INTERIM STORAGE: Design, construct and operate cyanide trans-shipping depots
                     and interim storage sites to prevent releases and
                     exposures.

Transport Practice 2.1: Store cyanide in a manner that minimizes the potential for
                           accidental releases.

                        X in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 2.1

                        �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
In terms of Cyanide Code definitions, SiLog does not have interim storage. However, vehicles
(tractors and tankers) are parked in a secure fenced area, within a wider Sasol Chemicals complex
security area, regularly patrolled by security and emergency response staff and with a HAZMAT
emergency response team only minutes away from the site.



3. EMERGENCY RESPONSE: Protect communities and the environment through the
                          development of emergency response strategies and
                          capabilities

Transport Practice 3.1: Prepare detailed emergency response plans for potential cyanide
                          releases.

                        X in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 3.1

                        �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
There is a procedure for handling off-site emergencies in place which consists of a 24 hour
Emergency call centre, flow chart process for handling off-site incidents and support information,
including all the necessary contact information and details for emergency response and local
authorities. There is also a Hazmat Emergency Stand-by List circulated weekly. There are also 16
approved Sasol Emergency Response providers who are available to provide emergency support
________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 7 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________
and response throughout South Africa. A network of emergency response trailers has been
located to cover all routes and these can be activated by trained representatives as first response
until the main Response Team arrives. The site itself has emergency response plans and all staff
and drivers are trained on the plans. Training and awareness for medical, emergency staff and
traffic officers provided to understand cyanide emergencies. Full cycle simulated accidents are
held regularly on different routes to test integrated response of authorities and partners.


Transport Practice 3.2: Designate appropriate response personnel and commit necessary
                          resources for emergency response.

                        X in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 3.2

                        �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
The tanker driver is fully trained in use of on-board PPE for use in emergencies. The equipment is
checked as a part of the vehicle checklist. A fully trained, dedicated emergency response team is
on permanent standby to respond to any incidents involving vehicles on delivery routes.
Specialised emergency response trailers have been located at fire stations on or near more remote
routes and are inspected annually or after use. Local emergency responders have been trained to
use the equipment until the dedicated emergency response team arrives. South African
Legislation requires that the driver receive Dangerous Goods certificate training every year.
Emergency Responders have a training and refresher programme which includes basic
HAZCHEM, SCBA unit usage, Rescue, Vehicles, Incident Control, ventilation, and credible
scenarios.


Transport Practice 3.3: Develop procedures for internal and external emergency
                        notification and reporting.

                        X in full compliance with

The operation is        �� in substantial compliance              with Transport Practice 3.3

                        �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
A centralized call centre manned 24 hours per day takes emergency calls and routes them
to appropriate persons and mobilizes the necessary response resources, according to
specific circumstances. Contact information is updated weekly.


Transport Practice 3.4: Develop procedures for remediation of releases that recognize
                         the additional hazards of cyanide treatment chemicals.
________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 8 of 9
Sasol Infrachem SiLog       TRANSPORTATION SUMMARY AUDIT REPORT
 th    th
7 -11 September 2009                                  Eagle Environmental
________________________________________________________________________

                      X in full compliance with

The operation is      �� in substantial compliance         with Transport Practice 3.4

                      �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
Procedures and guidelines are in place which covers remediation activities and the
hazards associated with cyanide treatment chemicals.


Transport Practice 3.5: Periodically evaluate response procedures and capabilities and
                          revise them as needed.

                      X in full compliance with

The operation is      �� in substantial compliance         with Transport Practice 3.5

                      �� not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:
Post incident reviews are carried out after drills and exercises and recommendations for
systems or procedure changes are made, as appropriate. Response procedures are control
documents in systems which include document control and regular formal review and
appropriate revision, if revision is not called for early, through drills and exercises.




________________________________________________________________________
Sasol Infrachem SILog      Signature Lead Auditor         6th January 2010
                                 Page 9 of 9

				
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