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Part III Annex D

Emergency Response Plan


Version 2.0

January 2015

Yara Dallol Potash Project, Danakil Depression,


Ethiopia

Document Ref. Prepared By Reviewed By Date Submitted to


Yara Dallol BV for
Review
0224244_V1.0_ERP Dieter Rodewald Mike Everett October 2014
0224244_V2.0_ERP January 2015

This report has been prepared by Environmental Resources


Management (ERM) the trading name of Environmental Resources
Management Southern Africa (Pty) Limited, with all reasonable skill,
care and diligence within the terms of the Contract with the client,
incorporating our General Terms and Conditions of Business and
taking account of the resources devoted to it by agreement with the
client.

We disclaim any responsibility to the client and others in respect of


any matters outside the scope of the above.
CONTENTS

LIST OF ACRONYMS 2

DEFINIITIONS 1-1

1 INTRODUCTION 1-1

1.2 PURPOSE AND SCOPE 1-3


1.3 LINKAGE TO OTHER ENVIRONMENTAL AND SOCIAL PLANS 1-3

2 SUMMARY OF LEGAL AND OTHER REQUIREMENTS 2-1

2.1 NATIONAL LEGISLATION AND POLICY 2-1


2.2 INTERNATIONAL FINANCE CORPORATION (IFC) PERFORMANCE STANDARDS 2-1

3 OVERALL ACCOUNTABILITY AND RESPONSIBILITY FOR THIS


PLAN 3-1

4 EMERGENCEY RESPONSE MANAGEMENT DURING THE


CONSTRUCTION, OPERATION AND DECOMMISIONING/CLOSURE
PHASES 4-1

4.1 HAZARD IDENTIFICATION RISK ASSESSMENT PROGRAMME 4-1


4.2 EMERGENCY COMMUNICATIONS AND COORDINATION PLAN 4-1
4.3 RESPONSE TO INCIDENTS 4-2
4.4 COSTS FOR EMERGENCY RESPONSE 4-4
4.5 ENVIRONMENTAL EMERGENCY PROCEDURES 4-4
4.6 EVACUATION PROCEDURE 4-6
4.7 VERIFICATION AND MONITORING 4-7
4.8 TRAINING 4-8
4.9 REPORTING AND DOCUMENTATION 4-8
4.10 INVESTIGATION AND FOLLOW-UP PROCEDURES 4-9
4.11 KEY PERFORMANCE INDICATORS 4-9

5 EMERGECY RESPONSE PLAN SUMMARY 5-1


LIST OF ACRONYMS

Abbreviation Full Definition


ANRS Afar National Regional State
APELL Awareness and Preparedness for Emergencies at Local Level
ERP Emergency Response Plan
ES-MS Environmental and Social Management System
ESIA Environmental and Social Impact Assessment
IFC International Finance Corporation
KPIs Key Performance Indicators
PS Performance Standard
SPCCP Spill Prevention, Control and Containment Plan
UNEP United Nations Environment Programme
DEFINIITIONS

The following definitions are of relevance within this report:

 Accident – an unintended incident which results in injury to persons


and/or damage to property, the environment, third party or which leads
to production loss.

 Emergency – a serious, unexpected and often dangerous situation which


poses an immediate threat to, personals, processes, assets, environment
and communities and requiring an immediate action.

 Employees – full time and part time employees of Yara Dallol BV (i.e. –
salaries paid directly to individuals by Yara Dallol BV).

 First Aid Injury – injury at work requiring first aid treatment only, before
the injured person resumes normal work.

 Lost-time Injury – injury at work leading to unfitness for work and


absence from the next scheduled work period.

 Incident – a sudden work related accident or near miss, a security breach


sustained in service. An injury or near-miss injury 'in service' means when
the incident occurs:

- On company property or on property under Yara operational


management.
- During transportation under Yara operational management.
- Within agreed working hours.
- On approved business trips.
- On approved training course or meeting at external location, or on
work assignment at customer's location.

 Medical Treatment Case – injury at work (other than a lost-time injury


and restricted work case) requiring treatment by a doctor, or nurse in
consultation with a doctor, before the injured person’s resumes normal
work.

 Near Miss – an unintended incident not leading to injury or damages, but


which under different circumstances could have become an accident.

 Restricted Work Case – injury at work that does not lead to absence from
the next scheduled work period, because of alternative job assignment.

 Security Breach – incidents which are illegal acts, intended to harm Yara
Dallol BV’s personnel, property, operations, transport or other interest.
 Site – refers to the area in which the Yara Dallol Potash Project operates,
including processing plant, evaporation ponds, tailings management area,
solution mining area, staff living quarters and the section of the Port of
Tadjoura under control of Yara Dallol BV.

 Yara Synergi Database - a Yara Dallol BV database for registration of all


incidents with injury of people, environmental incidents, incidents with
property damage or loss of production and security breaches. Incidents are
reported according to definitions and classification given in Yara TOPS 0-
01 “Reporting of Accidents, Near-miss Incidents, Sickleave, Environmental
Incidents and Security Breaches”

 Contractors – persons working for external companies (or employed by an


employment agency) that are under contract to carryout for the unit, but
not being part of the unit’s workforce.

 TOPS 0-01 – an existing Yara Dallol BV procedure titled “TOPS 0-01


Reporting of Accidents, Near-miss Incidents, Sick Leave, Environmental
Incidents and Security Breaches”

 TOP 0-02 – an existing Yara Dallol BV procedure titled “ Investigation and


Follow-up of Accidents and Near-miss Incidents”
1 INTRODUCTION

Yara International is a leading global fertilizer company with sales of fertilizer


to about 150 countries globally. As part of Yara International’s overall
upstream strategy, the company is exploring for suitable raw sources that can
be developed and used as a source to Yara International’s global fertilizer
production and directly as finished product in its product portfolio. To
complement these upstream processes, Yara International has recently started
a subsidiary company, Yara Dallol BV, which is involved in the exploration
and mining development of potash concessions in Ethiopia. These
concessions are located in the Danakil Depression, Afar National Regional
State (ANRS), Ethiopia. Yara International, through its subsidiary, proposes to
develop a potash mine – the Yara Dallol Potash Project (hereafter referred to
as the proposed Project) within these concession areas.

As part of the environmental approval process for the Project a suite of


environmental and social management plans is needed to address the issues
identified in the Environmental and Social Impact Assessment (ESIA). Several
management plans have been developed to address impacts identified in the
ESIA and are implemented as part of an environmental management system
for the proposed Yara Dallol Potash Project.

The following Emergency Response Plan (ERP) presents a framework


outlining procedures essential for effectively responding to process upset,
accidental, and emergency situations for operations and activities during
construction, operation and decommissioning and closure phases of the
Project. The procedures will include plans for addressing training, resources,
responsibilities, communication and all other aspects required to effectively
respond to emergencies associated with their respective hazards (flooding,
fire, political unrests, etc.) .

This ERP provides an outline to ensure that systems are in place so as to react
and appropriately manage unwanted outcomes. This ERP has been developed
to address the general requirements associated with efficient response to these
unwanted outcomes.

Yara Dallol BV will use this framework ERP to develop an operational plan
based on identified hazards.

1.1.1 Policy Statement

The development of this ERP has been guided by the Yara Dallol BV Health,
Environment, Safety, Quality and Product Stewardship Policy, as set out in
Box 1.1. This Policy is a high-level corporate statement of intent and
establishes the principles to be followed in the management of environmental
and health & safety issues.

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Box 1.1 Health, Environment, Safety, Quality and Product Stewardship Policy
Statement

COMPANY COMMITMENT

Yara Dallol BV’s aim is to establish sustainable growth and the creation of shareholder and
societal value. Yara Dallol BV affirms to their stakeholders, including employees, customers and
the public, it’s commitment to continuously improve and reach standards of excellence in
Health Environment, Safety, Quality and Product Stewardship through their operations.

ENVIRONMENTAL POLICY

Yara Dallol BV will manage their business in a life cycle perspective. In its operations Yara
Dallol BV will contribute to eco-efficiency by continuously improving energy consumption and
reducing waste, emissions and discharges. Waste that is generated will be handled and
disposed of safely and responsibly.

Yara Dallol BV will design their products and develop product applications to have the
minimum adverse effect on the environment throughout their lifecycle.

HEALTH AND SAFETY

Injuries and occupational illnesses, as well as safety and environmental incidents, are
preventable, and Yara Dallol BV’s goal for each of these is zero. Yara Dallol BV will encourage
their employees to adopt a healthy, safe life-style for themselves and their families.

Yara Dallol BV will be prepared for emergencies and cooperate with local authorities to
establish and improve their emergency preparedness.

1.1.2 Objectives

Yara Dallol BV has existing procedures/plans that deal with response


management to incidents and/or risks associated with aggressive (armed)
attack; kidnapping; detainment; hijacking; bombs / explosive remnants of
war; and medical emergencies. In addition to response management, Yara
Dallol BV has procedures that set out the actions required for incident
reporting, investigation and follow-up (these are described in further detail in
Section 1.3). These existing procedures/plans will be documented within the
overall ES-MS, and will be updated to include detailed response management
to the following emergencies –

 Fire
 Flash Flooding
 Chemical/Fuel Spills.

This ERP has the following objectives:

1. Protect the Yara Dallol BV employees, contractors, production process,


assets communities and the environment through the development of
emergency response strategies and capabilities.

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2. Set out the framework for hazard identification in order to define
procedures for response to the situations including the development of
contingency measures.

3. Structure a process for rapid and efficient response to and manage


emergency situations during the construction, operational and
decommissioning and closure phases of the Project.

4. Assign responsibilities for responding to emergency situations.

1.2 PURPOSE AND SCOPE

Activities undertaken during the construction, operation and


decommissioning phases of the Project have the potential to result in
unwanted outcomes and/or emergency situations. The ERP is aimed at
defining the response process and responsibilities for managing these
situations, thus reducing likelihood and severity of inadequate management.

This ERP is considered to be a “live” document and will need to be amended


periodically in light of operational changes, learnings experienced during its
implementation and other activities that can affect the risk profiles.

1.3 LINKAGE TO OTHER ENVIRONMENTAL AND SOCIAL PLANS

This ERP should be read in the context of the Environmental and Social
Management System (ES-MS) (discussed in Chapter 13 of Part I of the ESIA),
which has been structured to provide a vehicle for the integrated management
of the suite of management plans described in Part III. These plans have been
designed to address a broad range of social and environmental risks.

It is recognised that the ES-MS and associated plans are living tools that will
be constantly updated to accommodate changing circumstances.

The ERP links with the Spill Prevention, Control and Containment Plan,
SPCCP (Annex F in Part III). The SPCCP has reference with respect to the
development of emergency response processes that are associated with spills
and associated management within the Project and associated activities.
Moreover, this ERP links with the following existing Yara Dallol BV
plans/procedures -

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PLEASE NOTE

Yara Dallol BV has an existing Medical Evacuation Response Plan (MERP) for first and second
phase evacuation that has been developed and is managed by International SOS, and entails the
movement of the patient from the patient handover point to the nearest level of upgraded care
or the definitive medical facility. The MERP addresses medical emergencies only. It does not
cover other types of emergency planning, such as fires disaster response, environmental issues,
etc. Planning for second phase medical emergency evacuation links directly with this ERP and
must be considered as a follow on process to the Evacuation Procedure discussed in Section 4.6.

PLEASE NOTE

Yara Dallol BV has an existing Emergency Evacuation Pocket Guide (V1.0), which explains
preparation and reactive procedures that need to be taken in the event of an emergency
evacuation (such as civil unrest, terrorism, etc.). These evacuation procedures are associated
with getting personnel out of the Project Area and (if necessary) out of Ethiopia. Planning for
first and second phase emergency evacuation links directly with this ERP and must be
considered as a follow on process to the Evacuation Procedure discussed in Section 4.6.

PLEASE NOTE

Yara Dallol BV has an existing procedure (TOPS 0-01) that describes Yara Dallol BV procedures
for registration and reporting of accidents and near misses, security breaches, environmental
emissions and permit breaches and employee absence due to illness.

Moreover, Yara Dallol BV has set out a procedure (Yara TOPS 0-02) that describes the
requirements for investigation and follow-up of accidents and near miss incidents.

This ERP has been developed so as to compliment and makes reference to the requirements set
out in these two procedures.

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2 SUMMARY OF LEGAL AND OTHER REQUIREMENTS

A summary of the legal requirements and standards relevant to the ERP are
presented below.

2.1 NATIONAL LEGISLATION AND POLICY

The following Ethiopian regulation informed the development of this ERP:

2.1.1 Prevention of Industrial Pollution Council of Ministries Regulation


(159/2008)

This regulation is directed to industry and in particular “factories”. The


regulation does not provide a clear definition of “factories”; however, certain
sections of the regulation can be deemed applicable to the proposed Yara
Dallol Potash Project. These sections include the need for emergency response
systems and the need for monitoring of environmental safety.

2.2 INTERNATIONAL FINANCE CORPORATION (IFC) PERFORMANCE STANDARDS

The following IFC Performance Standards are applicable to this ERP:

2.2.1 Performance Standard 3 (Resource Efficiency and Pollution Prevention)

IFC Performance Standard (PS) 3 aims to avoid or minimise adverse impacts


on human health and the environment by avoiding or minimizing pollution
from project activities. Furthermore, the standard promotes more sustainable
use of resources, including energy and water and aims to reduce project-
related greenhouse gas emissions.

2.2.2 Performance Standard 4 (Community Health, Safety and Security)

IFC PS 4 aims to avoid adverse impacts on the health and safety of affected
community during the project life from both routine and non-routine
circumstances. Furthermore, the standard ensures that the safeguarding of
personnel and property is carried out in accordance with relevant human
rights principles and in a manner that avoids or minimises risks to the affected
communities.

The United Nations Environment Programme (UNEP) and Awareness and


Preparedness for Emergencies at Local Level (APELL) requires that all projects
will have an Emergency Preparedness and Response Plan that is
commensurate with the potential risks of the facility and that includes the
following basic elements:

 Administration (policy, purpose, distribution, definitions, etc.).

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 General Facility information including location, primary and alternate
emergency response coordinator, physical description of facilities,
surrounding and underlying geology and groundwater, description of
operations and processes, wastewater systems, facility outfalls, protection
of surface waters and personnel responsible for the development of the
contingency plan for the facility.

 Organization of emergency areas (command centers, medical stations,


etc.).

 Roles and responsibilities.

 Communication systems (such as a notification flow chart).

 Emergency response procedures to be used as guidelines to follow when a


spill, fire, explosion, or other catastrophic event causes a release of oil or
other hazardous materials to the environment.

 Emergency response procedures to be used as guidelines to follow when


there are spills in diked or containment areas, spills in un-diked areas,
spills to on-site ponds/trenches, spills on soil, spills to receiving riverbeds,
unplanned releases of compressed gases, and releases from oil-filled
electrical equipment.

 The identification and location of emergency response equipment, and


emergency response contractors, as well as descriptions of the appropriate
containment equipment to prevent spills from reaching water bodies.

 Emergency resources.

 Facility Evacuation Plan and diagrams.

 Training and updating requirements for facility operational and


emergency response personnel.

 Checklists (role and action list and equipment checklist including an


inventory of hazardous substances, wastes, oils, and industrial gases that
have a potential for spills or accidental releases into the environment).

ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV


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3 OVERALL ACCOUNTABILITY AND RESPONSIBILITY FOR THIS PLAN

With respect to this Plan, Yara Dallol BV has the responsibility to provide
emergency response services and to structure and coordinate emergency
response procedures for the Project, ensure that specific emergency
responsibilities allocated are organised and undertaken and ensure that
employees and contractor third parties are trained and aware of all required
emergency procedures.

The roles and responsibilities within Yara Dallol BV for the implementation of
the ERP are presented in Table 3.1.

Table 3.1 Responsible Parties and Roles and Responsibilities

Responsible Parties Roles and Responsibilities


 Review monthly and annual spill reporting
 Review emergency response drill outcomes and work with
Health and Safety Manager and Environmental and Social
Dallol General Manager Manager to identify necessary improvements
 Appoint an Emergency Response Coordinator tasked with
responding to emergencies in order to minimize disparate
utilization of resources
Emergency Response  Respond to emergencies so as to minimise disparate
Coordinator utilization of resources
 Ensure they are easily recognizable to their
colleagues/visitors and the emergency services by wearing
the orange high vis vest or coat during any evacuation
 Responsible for all occupants’ safety during evacuation and
to ensure the safety for personnel to reenter the building,
unless his role is passed onto the Emergency Response
Evacuation Officer Coordinator
 Keep an updated list of employees and visitors on site and
carry the name list with them during evacuation
 Ensure all occupants have evacuated the area where the
incident has taken place (including people in rest rooms,
meeting rooms, etc.)
 To be fully trained in the provision of first aid
 Distribution of the ERP to all parties with responsibilities in
implementing the plan (including contractors)
 Review monthly spill report
 Review quarterly report of accidents/incidents and reviews
of contractor practices
 Plan emergency response drills with Dallol General Manager
and Contractor Managers
Health and Safety  Develop Emergency Response Training
Manager  Lead any reviews or investigations into reported
accidents/incidents
 Review all contracts prior to signing and confirm these
contain requirements to meet Yara Dallol BV emergency
response standards
 Receive all notifications of incidents/accidents and ensure
proper response is being followed including reporting and
review

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Responsible Parties Roles and Responsibilities
 Support the Health and Safety Manager as required in
emergency response planning and in development of training
Environmental and Social
and management plans to ensure environmental concerns are
Manager
addressed
 Provide regular spill and accident reporting
 Schedule monthly inspections and audits and resolve issues
identified
Health & Safety Support
 Schedule emergency response training sessions for relevant
Staff
staff
 Prepare monthly spill report
 Provide local management and coordination of security for
personnel and operations in the field
 Deliver security induction briefings for visitors, including
international and Ethiopian employees, contractors and
contractors’ personnel
 Provide briefings and recurring security awareness training
for all personnel in security procedures, with specific focus
on their job role as per the project security plan
 Implement security risk mitigation measures and procedures
as per the security plan in order to reduce risk to as low as
reasonably practicable
 Maintain local security and emergency response and other
contingency plans to ensure they remain up-to-date
 When requested, assist with investigations on incidents
Security Manager
(including interviews, where necessary), writing clear reports
to be provided to management.
 Provide security support to Ethiopian and expatriate
personnel working at remote locations (e.g. drilling teams)
and provide field-level security advice and assistance with
planning
 Be the focal point for security issues in the field and at camp
 Execute community related tasks in consultation with Dallol
General Manager and ensure that good communication and
harmonious relationship with external stakeholders is
maintained
 Maintain and develop local information network to
understand concern from the local community and raise it to
site manager for resolution
 Together with the Health & Safety Manager and
Environmental and Social Manager is responsible for staffing,
planning and day-to-day execution of the management
measures described under this ERP during the construction
Project Manager phase of this Project.
 As needed, this individual will develop and propose staff
plans and contractual language to ensure that these measures
are implemented by Yara Dallol BV staff and contractors
throughout the construction phase of the Project.
 Together with the Health & Safety Manager and
Environmental and Social Manager is responsible for staffing,
planning and day-to-day execution of the management
measures described under this ERP during the operational
phase of this Project.
Operations Manager
 As needed, this individual will develop and propose staff
plans and contractual language to ensure that these measures
are implemented by Yara Dallol BV staff and contractors
throughout the operational phase of the Project.

ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV


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Responsible Parties Roles and Responsibilities
 Responsible for following the procedures and requirements
Contractors (Construction
indicated in construction and operational sections of this
and Operations)
ERP.
 All persons employed by Yara Dallol BV or under service
contract for Yara Dallol BV (e.g. contractor, transporter etc.),
All persons
who discover or cause an incident are responsible for
immediate reporting of the incident to his/her supervisor.

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4 EMERGENCEY RESPONSE MANAGEMENT DURING THE
CONSTRUCTION, OPERATION AND DECOMMISIONING/CLOSURE
PHASES

4.1 HAZARD IDENTIFICATION RISK ASSESSMENT PROGRAMME

Following completion of detailed design for the Project and prior to updating
the ES-MS system, Yara Dallol BV will develop a hazard identification risk
assessment programme, which will involve a baseline risk assessment of the
Project, from construction through to decommissioning/closure. This risk
assessment will aid in thorough risk identification. This risk assessment
programme will be repeated to take into account non-routine tasks, new
Project activities and changes made to the existing process.

Furthermore, Yara Dallol BV will co-ordinate the Project emergency response


process and will engage communities and local government to inform them of
the emergency response planning and processes, and integrate as appropriate
with available services.

4.2 EMERGENCY COMMUNICATIONS AND COORDINATION PLAN

In any emergency situation where there is an immediate threat to


communities, personnel or the environment, the Dallol General Manager shall
be notified immediately. The Dallol General Manager will dispatch the
Emergency Response Coordinator who will determine the appropriate plan of
action depending on the severity of the emergency, the people affected, and
the need to evacuate.

If there is a developing emergency or unusual situation, where an emergency


is not imminent, but could occur if no action is taken, the Dallol General
Manager (or if the Dallol General Manager is absent the Health and Safety
Manager or Environmental and Social Manager) is to be informed
immediately. Once the emergency or unusual situation has been managed, the
correct incident/near miss must be reported on to the Dallol General
Manager.

If an emergency situation poses a direct threat to communities in the area, the


Health & Safety Manager and Environmental and Social Manager will advise
persons in the vicinity of the emergency to evacuate due to the potential risk.
The appropriate authorities will immediately be notified of such an
emergency evacuation. The Emergency Response Coordinator will be tasked
with responding to the potential risk. Should the emergency situation be such
that it can be managed by Yara Dallol BV, equipment and personnel will be
deployed to the maximum extent necessary, so as to prevent/minimise
potential risks.

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Moreover, as per Yara Dallol BV’s existing procedure (TOPS 0-01), the
following incidents (as set out in Table 4.1) must be reported without delay by
the Dallol General Manager to the Yara International Head Office –

 All incidents and security breaches in severity class 1, 2 and 3; and


 All incidents with a potential for severity class 1 and 2.

4.3 RESPONSE TO INCIDENTS

An incident is any occurrence that has caused, or has the potential to cause, a
negative impact on people, the environment, property or production (or a
combination thereof). It also includes any significant departure from standard
operating procedures. The reporting and investigation of all potential and
actual incidents that could have a detrimental impact on human health, the
natural environment or property is required so that remedial and preventive
steps can be taken to reduce the potential or actual impacts as a result of all
such incidents.

The Yara Dallol BV procedure relating to the reporting of incidents (TOPS 0-


01) provides a classification of incidents into 5 categories of severity for the
following types of incidents (Table 4.1):

 Environmental incidents;
 Incident with injury of people;
 Incident with property damage or loss of production; and
 Security breach.

All incidents will be registered by using Yara’s Synergi database. Details of


this process are provided in the TOPS 0-01 procedure. Moreover, all incidents
will be investigated for identification of causes and preventative actions. All
investigations must be organised and carried out in accordance with Yara
Dallol BV’s procedure on investigation and follow-up of accidents and near
miss incidents (as detailed in TOPS 0-02).

The actions resulting from any formal or informal investigations will be used
to update this ERP.

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Table 4.1 Incident Categories (as per existing Yara Dallol BV procedures [TOPS 0-01])

Major Severity 1 Major Severity 2 Medium Severity 3 Medium Severity 4 Minor Severity 5
ENVIRONMENTAL INCIDENT
Accidental release of Release with serious short Release with the potential for Release with no apparent Minor release without
hazardous material, liquid or term environmental impacts short term local impact. environmental impact. environmental impacts or
gas to air, water or ground negative publicity.
with serious long terms National media coverage Local media coverage. Permit breach without legal
environmental impacts. charges.
Clean-up cost or legal Permit breach with the
International Media penalty in the range of 1 to potential for legal charges.
Coverage 10 million Euros (or 1.5 to 15
million USD).
Clean-up cost or legal
penalty of more than 10
million Euros (or more than
15 million USD).
INCIDENT WITH INJURY OF PEOPLE
Fatality Lost Time Injury with a Lost Time Injury without Restricted work case. First aid injury
serious injury consequence serious injury consequence.
(resulting in permanent or Medical treatment case.
long term disability)

INCIDENT WITH PROPERTY DAMAGE OR LOSS OF PRODUCTION


Economic loss in excess of 10 Economic loss in the range of Economic loss in the range of Economic loss in the range of Economic loss less than 0.01
million Euro. 1 to 10 million Euros (1.5 to 0.1 to 1 million Euros (or 0.15 0.01 to 0.1 million Euros (or million Euros (or less than
15 million USD). to 1.5 million USD). 0.015 to 0.15 million USD). 0.015 million USD).
International media
coverage. National media coverage.
SECURITY BREACH
Serious consequences for Serious consequences for Serious consequences for Serious consequences for Negligible consequences.
Yara Dallol BV with the Yara Dallol BV with the Yara Dallol BV with the Yara Dallol BV with the
equivalence environmental equivalence environmental equivalence environmental equivalence environmental
incident, incident with injury incident, incident with injury incident, incident with injury incident, incident with injury
of people, incident with of people, incident with of people, incident with of people, incident with
property damage or loss of property damage or loss of property damage or loss of property damage or loss of
production Major Severity 1. production Major Severity 4 production Major Severity 3 production Major Severity 4
Source: TOPS 0-01 Reporting of Accidents, Near-miss Incidents, Sick Leave, Environmental Incidents and Security Breaches

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4.4 COSTS FOR EMERGENCY RESPONSE

Costs for emergency response and associated management will be included in


the capital expenditure budget for the Project. This will include provision for
emergency situations during the construction, operational
decommissioning/closure phases of the Project.

4.5 ENVIRONMENTAL EMERGENCY PROCEDURES

As is detailed in Section 1.3 on Page 1-3, Yara Dallol BV has existing


procedures/plans that deal with response management to incidents and/or
risks associated with aggressive (armed) attack; kidnapping; detainment;
hijacking; bombs / explosive remnants of war; and medical. These existing
procedures/plans will be documented within the overall ES-MS, and will be
updated to include detailed response management to the following additional
emergency events –

 Fire
 Flash Flooding
 Chemical/Fuel Spills.

These three additional emergency event categories can be defined as follows:

 Fire – an event where an object or objects are ignited by a source and burn
with a flame or where smoke is visible.

 Flash Flooding – flash flooding is common in the area of the Project and is
an event where non-perennial rivers (viz. the Musley River) flood during
high rainfall flash flood events in the western highlands.

 Chemical/Fuel Spills – when any chemical or fuel is accidently released


into the natural environment.

The purpose of these procedures is not to detail exact measures for every
scenario as this is known to be impractical. Response personnel must be able
to develop in situ the specific response strategies for individual scenarios,
whilst relying on the generic guidelines and support measures described in
this Plan.

4.5.1 Fire

The following emergency procedures must be implemented when fire


occurrence (or evidence thereof) is noted in the immediate vicinity of the
Project Area during the construction, operational and
decommissioning/closure phases:

 The Emergency Response Coordinator must be notified.

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 Personnel in the immediate vicinity of the fire, including the designated
Evacuation personnel must be immediately notified.

 All persons located in the area in which the fire is located must be
evacuated. Evacuation must be carried out as per the Evacuation
Procedure (Section 4.6).

 All doors and windows of buildings and vehicles that are in the immediate
vicinity of the fire must be closed.

 The fire must be contained with the correct extinguisher ONLY by those
trained to do so.

 Those requiring assistance must be assisted and first aid must be rendered
ONLY by those trained to do so.

 Those confined to an area where there is smoke, must move under the
level of the smoke and cover their nose/mouth.

4.5.2 Flash Flooding

Proactive Management Measures

The following proactive actions must be carried out to understand the risks of
flash flooding for the Project:

 Develop an understanding of the potential flash flood events to which the


site of the Project is exposed – i.e. flood events associated with the non-
perennial Musley River and surrounds.

 The weather forecast in the surrounding highlands must be constantly


monitored, especially during the wet season.

 All key equipment must be raised above (or away) expected flash flood
levels.

 Construction of bund and water channels to divert flood water to safe


areas.

Yara Dallol BV will ensure that Proactive measures to prevent flooding will
not be in contravention to the requirements as set out in the ESIA and
associated water, biodiversity and social management plans.

Emergency Procedures

In the event of a flash flood onsite, the following emergency procedures will
be implemented:

 The Emergency Response Coordinator must be notified.

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 All personnel onsite, including the designated Evacuation personnel must
be immediately notified.

 All equipment must be safely shutdown and all electrical equipment must
be isolated.

4.5.3 Chemical/Fuel Spills

A standalone Spill Prevention, Control and Containment Plan (SPCCP) has


been developed (refer to Annex F in Part III). This plan will be used to address
the general requirements for management of unplanned spills of dangerous or
hazardous materials has been generated.

4.6 EVACUATION PROCEDURE

All staff must be aware of the possible escape routes prior to the emergency
situation. Always assure safety of the assembly point prior to evacuation. The
procedure associated with an evacuation event is detailed below:

 The Emergency Response Coordinator will give instruction or the alarm


will sound to evacuate a specific area.

 All staff appointed as Evacuation Officers must assist with the evacuation.

 All personnel onsite must follow the instructions of the Evacuation Officer.

 Personnel must follow the directional pointers to the nearest emergency


exit.

 Evacuation must be undertaken in accordance to the emergency lay out


plan.

 Mobile employees must be the first to be evacuated followed by the frail


and the injured.

 Evacuation personnel must work in pairs where possible to assist one


another lifting heavy injured employees.

 Mobile employees who are struggling or appear unsure must be assisted.

 Personnel must evacuate by walking briskly and must not run.

 Evacuating personnel must stay calm and must not panic. Panic can
spread and cause unnecessary chaos.

 Evacuating personnel must always keep left along the evacuation routes.

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 In the case where the emergency situation results in fire or smoke,
evacuating personnel must consider crawling, as this may be better than
walking.

 Visitors that are not familiar with the evacuation procedure must be
assisted.

 A daily record of staff and visitors must be kept.

 The task of the professional Emergency Services must not be obstructed.

 If necessary, a search / check for all unaccounted personnel must be


undertaken before leaving the area.

 The evacuation officer must be the last one to leave the area.

 All personnel onsite must report directly to the allocated assembly point.

 Personnel must not leave the assembly point until it has been deemed safe
to do so.

4.7 VERIFICATION AND MONITORING

The Health and Safety Manager has been tasked with the responsibility for
auditing the Project and implementation of emergency response procedures
associated with all phases of the Project. The execution of emergency drills
will be included in Yara Dallol BV’s emergency response procedures. These
will include the following:

 Fire Drills;
 Flash Flooding Drills;
 Aggressive (armed) Attack Drills;
 Medical Drills;
 Chemical / Fuel Spill Drills; and
 Emergency Evacuation Drills.

Reporting and monitoring requirements for the ERP will include:

 Monthly inspections and audits;

 Quarterly report of accidents/incidents;

 Reporting at the time of any environmental incidents;

 Bi-annual emergency response drills; and

 Annual reporting on training.

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Emergency response drills and reporting maintained by the Health & Safety
and Environmental and Social Managers will provide information regarding
required revisions to training or the emergency response actions. Each
incident reported will be reviewed and investigated upon occurring. Actions
will be identified where possible to improve the site’s overall response to
emergencies.

Updates/revisions that are necessary to protect worker or community health


and safety will be implemented immediately after approval by the Dallol
General Manager. On a bi-annual (twice annually) basis Key Performance
Indicators (KPIs) will be compared against past-performance and analyzed for
trends to determine if there are areas the can be improved.

Changes as a result of the trend analysis and identified areas for improvement
will be implemented following the Project’s change management system as
required.

4.8 TRAINING

All employees and contractors will be trained in emergency response


procedures within one month of their start-date. The Health and Safety
Manager shall distribute the ERP (together with the associated Emergency
Evacuation Plan) to all parties in charge of ensuring the plans implementation.
All relevant information in the ERP (and associated Emergency Evacuation
Plan) shall be communicated to employees and contractors. This information
shall include information on potential emergency risks/threats, appropriate
first person response to incidents/emergencies and notification procedures.

All site personnel, including contractors, are to be trained in the appropriate


responses for emergencies. The training is mandatory and is to be conducted
on a regular basis. The frequency and timing of training is at the discretion of
the Dallol General Manager, Health and Safety Manager and Environmental
and Social Manager, but is to take place at least once a month.

Training is to include, but not limited to the following:

 Firefighting;
 First Aid;
 Emergency Evacuation; and
 Medical and Environmental Emergencies.

4.9 REPORTING AND DOCUMENTATION

Monitoring reports against the Plan will be reported by the Yara Dallol BV
Health and Safety Manager and Environmental and Social Manager. These
reports must within five working days of month end be registered on Yara

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Dallol BV’s Synergi database. The registering of incidents must be carried out
in conformance with TOPS 0-01.

4.10 INVESTIGATION AND FOLLOW-UP PROCEDURES

In addition to the above mentioned reporting and documentation


requirements, Yara Dallol BV will implement the investigation and follow-up
requirements set out in the TOPS 0-02 procedure.

4.11 KEY PERFORMANCE INDICATORS

The following KPIs will be measured and used to evaluate the Project’s
performance with respect to its stated objectives and commitments:

 Number of identified non-compliances with emergency prevention and


preparedness measures identified in this Plan;

 Number of incidents that have triggered the emergency response


procedure; and

 Specific KPIs in relation to compliance with emergency prevention


measures.

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5 EMERGECY RESPONSE PLAN SUMMARY

Table 5.1 Complete Project Lifecycle

Impact Objective Mitigation/Management Measures Monitoring Plan Responsibility


Potential negative impacts Updating and Review of the ERP to confirm specific  Annual review  Dallol General
to the environment, implementation of a procedures are in place to address, Manager
workforce and community suitable ERP natural disasters, security breaches,  Health and Safety
from emergencies kidnapping, aggressive armed attack, Manager
detainment, hijacking, bombing, medical  Security Manager
emergencies, fires, traffic incidents, and
spills/releases of fuels and hazardous
substances.
Update the ERP Review of the ERP in the event of a  Review of the ERP in  Health and Safety
change in process within the mining or the event of a change Manager
support operations in process within the
mining or support
operations
Manage the ERP processes Maintenance of emergency contact  Annual review of  Environmental and
information, emergency / evacuation processes Social Manager
instructions, location of response  Health and Safety
equipment Manager
Manage the ERP processes Maintenance of emergency response  Annual inspection of  Health and Safety
equipment equipment Manager
Provide emergency Provide emergency response and  Response reporting  Health and Safety
response and evacuation evacuation training to all employees and training Manager
training contractors, including first aid training
 Annual review of
candidates

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Impact Objective Mitigation/Management Measures Monitoring Plan Responsibility
Provide emergency Provide all personnel involved in the  Response reporting  Health and Safety
response and evacuation Project appropriate training on how to training Manager
training recognise and respond to situations which
can result in a risk to them, communities  Annual review of
or the environment candidates

Provide ERP relevant Emergency Response Drills  Implementation of  Health and Safety
training monthly emergency Manager
response drills for
relevant personnel

Report on emergencies Carryout the appropriate internal and  Review of all incidents  Health and Safety
external reporting / accidents reports Manager

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