Waste Management Plan September 2011 45-PL-EN-0014 Waste Management Plan TABLE OF CONTENTS 1. INTRODUCTION .......................................................................................... 1 1.1 REQUIREMENTS FOR A WASTE MANAGEMENT PLAN ·········································· 1 1.2 OBJECTIVES & SCOPE ······················································································ 1 1.3 LEGISLATIVE AND REGULATORY FRAMEWORK··················································· 2 2. ROLES AND RESPONSIBILITIES ............................................................. 4 3. STAKEHOLDER CONSULTATION ........................................................... 4 4. KEY ENVIRONMENTAL ACTIVITIES ........................................................ 5 5. POTENTIAL ENVIRONMENTAL IMPACTS .............................................. 5 6. ENVIRONMENTAL MANAGEMENT .......................................................... 6 7. MONITORING GUIDELINES .................................................................... 11 8. AUDIT .......................................................................................................... 11 9. CORRECTIVE ACTIONS .......................................................................... 12 10. REVIEW ................................................................................................... 12 11. REFERENCES ........................................................................................ 13 LIST OF TABLES Table 1 Commonwealth and State Legislation Relating to Waste Table 2 Potential Environmental Impacts of Waste Arising from Fortescue’s Activities Table 3 Description of key elements of environmental management process to achieve identified objectives Table 4 Key Management Actions for Waste in Fortescue’s Operations Area LIST OF FIGURES Figure 1 Relationship between the objectives set out in this Waste Management Plan and the Waste Hierarchy 45-PL-EN-0014 Rev1 Page ii Waste Management Plan LIST OF APPENDICES Appendix A Fortescue Metals Group Background Appendix B Data Flow Diagram Appendix C Cross reference to Ministerial Statement Requirements Appendix D Sustainable Packaging Guideline Templates Appendix E Reporting Guidelines 45-PL-EN-0014 Rev1 Page iii Waste Management Plan 1. INTRODUCTION Fortescue Metals Group (Fortescue) is an integrated business comprised of mine, rail and port operations based in the Pilbara region of Western Australia, with its head office located in Perth. Detailed background information regarding the timing and nature of Fortescue’s environmental approvals under the Environmental Protection Act 1986 (WA), the Environment Protection and Biodiversity Conservation Act 1999 (Cth), current operations and plans for future expansion is contained in Appendix A. 1.1 REQUIREMENTS FOR A WASTE MANAGEMENT PLAN This Waste Management Plan (WMP) is required by the Minister for the Environment as part of the development approval of Fortescue’s operations in the Pilbara. Existing projects and future developments are required to prepare and implement site-specific Waste Management Programs to support this WMP. The data flow diagram for this Plan is available in Appendix B. 1.2 OBJECTIVES & SCOPE The objective of the WMP is to minimise direct and indirect impacts of waste. The WMP was initially developed to meet the requirements of Commitments 26 and 27 in Schedule 2 of Ministerial Statement 721. Additional commitments and requirements relating to waste management were generated in later environmental approvals processes, all of which are summarised in Appendix B. The overall objective being: “ensuring that the disposal and management of wastes do not adversely affect environmental values or the health, welfare and amenity of people and land uses, by meeting statutory requirements and acceptable standards”. For the purpose of this WMP, waste may mean one or more of the following, but excludes waste rock from overburden: any substance that is discarded, emitted or deposited in the environment in such volume, constituency or manner as to cause an alteration in the environment; any discarded, rejected, unwanted, surplus or abandoned substance; 45-EN-PL-0014 Rev 1 Page 1 Waste Management Plan 1.3 any otherwise discarded, rejected, unwanted, surplus or abandoned substance intended for sale or for recycling, reprocessing, recovery, or purification by a separate operation from that which produced the substance; any substance described in regulations under the Environmental Protection Act 1986 as waste. LEGISLATIVE AND REGULATORY FRAMEWORK Fortescue’s employees and contractors are obliged to comply with all environmental Commonwealth and State legislation. There is a range of legislation that relates to the treatment, handling and disposal of waste in Western Australia (Table 1). Table 1: Commonwealth and State Legislation Relating to Waste State Government Legislation Environmental Protection Act 1986 (WA) Application Part IV - Environmental Impact Assessment (EIA) and implementation of proposals; Part V – Environmental regulation of pollution, prescribed premises, works approvals and licences. Environmental Protection Regulations 1987 (WA) Part III - General control of pollution (administration, works approval, licensing & registration of prescribed premises); Part VI - Disposal of tyres. Environmental Protection (Rural Landfill) Regulations 2002 (WA) Applicable to the construction and management of registered Putrescible Landfill Sites with a design capacity of more than 20 but less than 5000 tonnes per year (i.e. prescribed premises category 89). Environmental Protection (Unauthorised Discharges) Regulations 2004 (WA) Defines materials which must not be burnt or discharged into the environment. Environmental Protection (Controlled Waste) Regulations 2004 (WA) Obligations relating to the transportation and disposal of ‘controlled’ (generally hazardous) wastes. Controlled wastes listed in Schedule 1 of the Regulations. Environmental Protection (NEPM UPM) Regulations 2003 (WA) Details recycling measures to comply with the National Environmental Protection Measure on Used Packaging Materials, which supports the National Packaging Covenant. Iron Ore (FMG Chichester Pty Ltd) Agreement Bill 2006 (WA) Mining proposals subject to Environmental Protection Act 1986 45-EN-PL-0014 Rev 1 Page 2 Waste Management Plan State Government Legislation Application Health Act 1911 (WA) Regulates the use of apparatus for the treatment and disposal of sewage Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974 (WA) Applicable to the construction or installation of apparatus for the treatment of sewage and disposal procedures Health (Asbestos) Regulations 1992 (WA) Procedures for the disposal of material containing asbestos Litter Act 1979 (WA) Defines actions legally considered as littering and associated penalties Mining Act 1978 (WA) Regulation and imposition of environmental conditions on mining tenements. The following Fortescue documents are also of relevance to this plan: - Battery Recycling Procedure (M-PR-EN-0008); - Cardboard Recycling Procedure (M-PR-EN-0009); - Chemical and Hydrocarbon Management Plan (45-PL-EN-0011); - Cloudbreak Waste Disposal Procedure (204-03-EN-PP-0002); - Fluorescent and other Globe Recycling Procedure (M-PR-EN-0011); - Incident Event Reporting Procedure (100-PR-SA-0011); - Landfill Siting Criteria Specification (100-RP-EN-9540); - Paper Recycling Procedure (M-PR-EN-0014); - Plastics Recycling Procedure (M-PR-EN-0015); - Printer Cartridge Recycling Procedure (M-PR-EN-0018); - Procurement Policy (100-PO-PC-0001); - Scrap Metal Recycling Procedure (M-PR-EN-0016); - Used Earthmoving Equipment Tyre Disposal (M-PR-EN-0022). 45-EN-PL-0014 Rev 1 Page 3 Waste Management Plan 2. ROLES AND RESPONSIBILITIES All Fortescue employees and contractors are required to comply with the requirements of this Plan. Accountability for fulfilling the requirements of this WMP is dependent on the stage of project development (construction, operations, decommissioning) and the project type (port, rail, mine). During construction stages, whether activities are undertaken by an external service provider or internal Fortescue personnel, the Project Manager will be accountable for ensuring the requirements of this WMP are met. During operational stages, the General Manager (Port/ Rail or Mine) will be accountable for ensuring the requirements of this WMP are met. Where responsibilities are delegated, this must be clearly recorded and communicated. Table 4 attributes specific Management Actions to the appropriate personnel. 3. STAKEHOLDER CONSULTATION Due to the isolation of Fortescue’s mining operations and lack of adjacent sensitive community receptors, the Department of Environment and Conservation (DEC) is the stakeholder with a vested interest in waste management. However, Fortescue will openly consult with any adjacent land user that legitimately has a vested interest in off-site waste management impacts. Furthermore, Fortescue may also participate in the development and implementation of viable regional waste management strategies should such an activity be instigated. An earlier version of this WMP was submitted to the DEC for feedback. This WMP will be submitted to the Office of the Environmental Protection Authority (OEPA) for their information. 45-EN-PL-0014 Rev 1 Page 4 Waste Management Plan 4. KEY ENVIRONMENTAL ACTIVITIES Many of the activities 1 associated with Fortescue’s exploration, construction, operation and decommissioning activities have the potential to impact on the environment. Key activities across Fortescue’s operations which have the potential to generate waste that requires disposal and management include: 5. - Construction/establishment of infrastructure; - Mining; - Maintenance; - Accommodation; - Materials delivery and handling; - Chemical and hydrocarbon spills; and - Waste disposal. POTENTIAL ENVIRONMENTAL IMPACTS The key potential impacts of waste arising from Fortescue’s activities are presented in Table 2. Table 2: Potential Environmental Impacts of Waste Arising from Fortescue’s Activities Potential Environmental Impact Soil Contamination Details Leaching of organic acids to soils, Leaching of heavy metals to soils, Leaching of oils & hydrocarbons to soils. Fauna Health Feral invaders, Native fauna attracted to landfill areas, Hazardous materials, Waste. 1 Fortescue uses the term ‘activities’ to refer to ‘Environmental Aspects’ as defined by ISO14001 45-EN-PL-0014 Rev 1 Page 5 Waste Management Plan Amenity Dust (visual amenity), Terrestrial land change (visual amenity), Windblown rubbish (visual amenity), Smell. Surface water contamination Surface water interruption, Run-off of organic acids in surface water, Run-off of heavy metals in surface water, Run-off of oils & hydrocarbons in surface water. Ground water contamination Ground water interruption, Leaching of organic acids to ground water, Leaching of heavy metals to ground water, Leaching of oils & hydrocarbons to ground water. Greenhouse gas emissions 6. Emissions of methane and other greenhouse gasses to atmosphere. ENVIRONMENTAL MANAGEMENT A series of environmental objectives have been developed to mitigate environmental impacts of waste resulting from Fortescue activities (exploration, construction, operation and decommissioning). These objectives include: 1. Procurement of materials, aimed at minimising the generation of waste from the use of these materials, 2. Re-use and recycling of materials to be undertaken wherever practicable and feasible, 3. Handling and treatment of waste prior to re-use and/or disposal to landfill or hazardous waste receptors. For each objective, management actions have been developed to ensure the impacts from Fortescue’s operations are managed, and that appropriate reporting and corrective action functions are implemented to support the successful implementation of the management actions. The key elements of the environmental management process associated with each objective are described in Table 4. Table 3 below, defines the framework used to meet the three objectives described above. 45-EN-PL-0014 Rev 1 Page 6 Waste Management Plan Table 3: Description of key elements of environmental management process to achieve identified objectives. Element Definition / Description Objective What is intended to be achieved. Management Action Tasks undertaken to enable the objective to be met. Performance Indicators Metrics for evaluating the outcomes achieved by the Management Action. Reporting/Evidence Demonstrates that the Management Action has been applied and the outcome evaluated. Timing Period during which Management action should be undertaken. Responsibility Accountability for ensuring the management action is completed. 45-EN-PL-0014 Rev 1 Page 7 Waste Management Plan Table 4: Key Management Actions for Waste within Fortescue’s Operations Area2 Objective 1 Procurement of materials, aimed at minimising the generation of waste from the use of these materials. Reference Management Action Performance indicators Reporting / Evidence Timing Accountability Ensure Terms and Conditions of all contracts contain waste management and waste minimisation clauses. Contractors packaging & refuse obligations to be included in Contract document Terms and Conditions Contract Terms and Conditions Ongoing over project duration Procurement Manager 1.1 Two major products / suppliers reviewed each year Completed SPG template Procurement Manager Report of product/supplier review Annually over project duration 1.2 When appropriate, use the Sustainable Packaging Guidelines (SPG) to reduce packaging for specifics products / suppliers. The SPG template is followed and completed Undertake annual reporting / evidence reviews for Reference points 1.1 to 1.2. Annual review of preferred products log conducted Preferred products log Annually over project duration Procurement Manager Reporting / Evidence Timing Accountability Ongoing over project duration HSES Manager 1.3 Objective 2 Re-use and recycling of materials to be undertaken wherever practicable and feasible Reference Management Action Performance indicators Develop site specific Procedures for all material streams to ensure compliance, accountability and internal processes are maintained. Procedures documented and adhered to Annual audit compliance reports 2.1 Compliance, accountability and internal processes maintained Site waste management procedures 2.2 Provide appropriate signage to direct segregation of waste into bins / receptacles. Bins / receptacles have appropriate signage. Quarterly site Inspection Reports Ongoing over project duration Manager, Infrastructure Services Ensure employee and contractor inductions outline key aspects of the WMP, including the waste hierarchy (refer to Diagram 1). Key aspects of WMP included in induction and training modules , including toolbox meetings Employee / Contractor inductions 2.3 Toolbox meeting minutes Ongoing over project duration HSES Manager/ Human Resources Manager Where practicable, recycle and/or re-use viable materials, considering transport costs, sale price and indirect savings. Costing and implementation reports completed Costing and implementation reports Project Duration HSES Manager Monthly waste report Site Inspection Reports Project Duration Monthly waste report Manager, Infrastructure Services 2.4 2.5 2 Waste to landfill is reduced Make recycling facilities available in office, workshop and camp areas for any viable recyclable materials including: Recycling facilities are available for viable recyclable items Glass; paper; aluminium cans; scrap metal; and/or any other viable materials. Waste to landfill is reduced Fortescue’s Operations Area is linked to specific Fortescue mining and infrastructure projects, and is defined as mining/infrastructure areas and surrounds subject to project related disturbance. 45-EN-PL-0014 Rev 1 Page 8 Waste Management Plan Ensure workshops, offices, camp areas and / or other applicable mine site areas and/or the central waste management facility have designated bins or stockpiles (as appropriate) for recyclable or re-usable materials including: 2.6 Separate receptacles or stockpile areas are available for recyclable / re-usable items. Quarterly site Inspection Reports Monthly waste report Ongoing over project duration Manager, Infrastructure Services Annually during operations HSES Manager Reporting / Evidence Timing Accountability Waste to landfill is reduced Annual review performed. Annual Review Report Program updated where necessary Annual Environmental Report Oily waste; batteries; tyres; wooden pallets; vegetative waste; aluminium cans; scrap metals; glass; paper; cardboard and/or any other viable materials. Conduct an annual review of recycling programs at office, workshop, mine and other mine site areas to consider net environmental outcomes, cost effectiveness, contamination rates and collection effectiveness. Where necessary revise the program(s) to address outcomes of the review. 2.7 Objective 3 Handling and treatment of waste prior to re-use and/or disposal to landfill or hazardous waste receptors Reference Management Action Performance indicators 3.1 Follow the Landfill Siting Criteria Specification (100-RP-EN9540) when siting new Fortescue landfill facilities. Landfills are sited in accordance with the landfill siting criteria Completed checklist of site conditions versus siting criteria Prior to landfill construction. Manager Environmental Approvals Chemical and hydrocarbon waste managed in accordance with the Chemical and Hydrocarbon Management Plan Quarterly audit compliance reports Site chemical and hydrocarbon management procedures Ongoing over project duration 3.2 Adhere to the Chemical and Hydrocarbon Management Plan (45-Pl-EN-0011) when handling, storing and transporting chemical and hydrocarbon wastes and for response procedures in relation to accidents/incidents and spills involving these types of waste. Manager Infrastructure Services / Logistics Manager Incident reports completed Incident reports Submit works approval and registration/licence applications to construct and operate any on-site Landfill Facility to the DEC. Works approval and registration/licence applications made 3.3 Works Approval and Registration/licence applications. Prior to Landfill Construction Manager Environmental Approvals On-site landfill constructed as a registered Class II Facility Works approval and registration/licence applications Ongoing over project duration Manager Infrastructure Services 3.4 Any on-site landfill will be constructed as a registered Class II (unlined) Facility and designed, operated and closed in accordance with the Environmental Protection (Rural Landfill Regulations) 2002 or other approval issued by the regulator(s). Compliance with the Regulations or other approval issued by the regulator(s) Updated site environmental audit reports Quarterly audit compliance reports Develop site specific waste management procedures to ensure compliance, accountability, and correct waste treatment / disposal is maintained. Procedures are documented. Waste Management Procedures 3.5 Ongoing over project duration Manager Infrastructure Services Designated bins for general putrescible waste (fitted with secure lids), including food scraps, will be made available within all office, workshop and camp areas. Separate lidded receptacles are available for general putrescible waste. Quarterly site Inspection Reports 3.6 Ongoing over project duration Manager Infrastructure Services 45-EN-PL-0014 Rev 1 Page 9 Waste Management Plan General putrescible and inert wastes (or other wastes meeting specific waste acceptance criteria) will be disposed to an appropriate Landfill Facility, either on-site or off-site. 3.7 3.8 Ensure storage, handling, collection and/or transport of controlled wastes (e.g. septage wastes, Class IV or V contaminated soils, low strength waste waters, asbestos, pesticides, paints etc) is in compliance with Environmental Protection (Controlled Waste) Regulations 2004. Record the monthly volume of waste generated and disposed of either on-site or off-site in accordance with the Reporting Guidelines in Appendix E. 3.9 45-EN-PL-0014 Rev 1 All landfill waste disposed to an appropriate Facility Quarterly site Inspection Reports Disposal records Handling and disposal of controlled wastes in compliance with the Controlled Waste Regulations. Quarterly audit compliance reports Controlled waste tracking forms Site waste management procedures Monthly volumes of all waste streams recorded Monthly waste and recycling report Annual Environmental Report. Ongoing over project duration Manager Infrastructure Services Ongoing over project duration Manager Infrastructure Services / Logistics Manager Monthly over project duration Manager Infrastructure Services Page 10 Waste Management Plan Diagram 1: Relationship between the objectives set out in this Waste Management Plan and the Waste Hierarchy. Remove Reduce Reuse Recycle Recover Dispose 7. REPORTING GUIDELINES Guidelines for reporting wastes generated and disposed of either on-site or off-site can be found in Appendix E. By adopting these guidelines a consistent reporting approach can be applied across all of Fortescue Operations. 8. AUDIT Internal auditing of activities associated with the WMP will be carried out in accordance with Fortescue’s internal audit schedule. Audit criteria may include, but is not limited to the compliance of the: Management actions within this document; Implementation of site specific monitoring programs; and Applicable conditions and commitments within Ministerial Statements. 45-EN-PL-0014 Rev 1 Page 11 Waste Management Plan Where non-conformance issues or opportunities for improvement are identified these will be documented and tracked via the Business Management System (BMS). 9. CORRECTIVE ACTIONS While it is anticipated that the measures detailed in this Plan will be adequate to ensure that the disposal and management of wastes do not adversely affect health, amenity or environmental values, Fortescue recognises that it is best practice to develop contingency actions which are to be implemented upon the identification of potential non-conformances with the intended waste management measures. Results from successive monitoring events will be used to develop and refine management triggers and thresholds. Contingency measures will be triggered in the event of two or more survey events revealing significant decline in relevant environmental factors. Expert opinion will be sought if and when required, to guide contingency measures. By understanding why certain management strategies do not work, specialist advice can be used to modify these and develop new measures. Any incidents arising from unauthorised waste management shall be considered an incident and reported and investigated as per Incident Event Reporting Procedure (100-PR-SA-0011). The cause of the incidents will be determined and management procedures will be modified, and measures taken (as required) to prevent reoccurrence of incidents. 10. REVIEW It is important that plans and procedures are frequently reviewed and revised as Fortescue’s operations change and opportunities for improved management practices are identified. This WMP will be reviewed every 5 years, or when significant additional information comes to hand. Upon review, the document will be revised where appropriate and the revision status will be updated in accordance with Fortescue’s document control procedures. 45-EN-PL-0014 Rev 1 Page 12 Waste Management Plan 11. REFERENCES DEC (2005a). Landfill Waste Classification and Waste Definitions (As Amended). Department of Environment and Conservation. DEC (2005b). Siting, Design, Operation and Rehabilitation of Landfills (Draft). Department of Environment and Conservation. DEC (2006a). Compliance Monitoring and Reporting Guidelines for Proponents: Preparing Environmental Management Plans (Draft). Compliance Monitoring Guidelines Series, Department of Environment and Conservation. ENVIRON (2004). Public Environmental Review: Pilbara Iron Ore and Infrastructure Project: Port and North-South Railway (Stage A). Report prepared for Fortescue Metals Group. ENVIRON (2005a). Public Environmental Review: Pilbara Iron Ore and Infrastructure Project: Stage B East-West Railway and Mine Sites. Report prepared for Fortescue Metals Group Limited. ENVIRON (2005b). DRAFT Public Environmental Review: Pilbara Iron Ore and Infrastructure Project: Cloud Break. Report prepared for Fortescue Metals Group Limited. APC (2010) Sustainable Packaging Guidelines. Accessed from, <http://www.packagingcovenant.org.au/documents/File/Sustainable%20Packaging %20Guidelines%20-%201%20Jul%2010.pdf> Australian Packaging Covenant. Accessed: March 2011. 45-EN-PL-0014 Rev 1 Page 13 Appendices Appendix A. Fortescue Metals Group Background Fortescue Metals Group Background Fortescue Metals Group (Fortescue) is an integrated business comprised of mine, rail and port operations based in the Pilbara region of Western Australia with its head office located in Perth. Fortescue has commenced operation of the Pilbara Iron Ore and Infrastructure Project (the Project), which consists of several iron ore mines and associated rail and port infrastructure in the Pilbara region of Western Australia. The Project was granted Major Project Facilitation Status in December 2004 and Fortescue has signed two Agreements with the State of Western Australia: The Railway and Port (The Pilbara Infrastructure Pty Ltd) State Agreement for the port and rail infrastructure to transport ore from the mines to the port, and The Iron Ore (FMG Chichester Pty Ltd) Agreement for the iron ore mines. The project has been developed in four stages: Stage A, consisting of a two-berth iron ore export facility at Port Hedland and a north-south railway (not completed) from the central Pilbara to Port Hedland, approved under Ministerial Statement 690; Stage B, consisting of iron ore mines in the eastern Pilbara (Christmas Creek) and an east-west spur rail line connecting to the Stage A railway; approved under Ministerial Statement 707. (Note this approval included the Mindy Mindy mine site but this has not been developed to date); Cloudbreak iron ore mine west of the Christmas Creek area, approved under Ministerial Statement 721; Port facility upgrade consisting of a third berth at Anderson Point, Port Hedland, approved under Ministerial Statement 771. Changes to Ministerial Statements 690, 707 and 721 were approved under Section 45C of the Environmental Protection Act 1986 (EP Act) in 2009 (Ministerial Statement 690) and 2010 (Ministerial Statement 707 and 721). The project has also received approval under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). Fortescue is extending its current operations in the Pilbara with the expansion of its Chichester mines and the development of the Solomon Project, which includes two new mine sites (Firetail and Kings), and a rail line to support the new sites. The Solomon Project area (Solomon) is located approximately 60 kilometres (km) north of Tom Price and is situated on both sides of the rail line operated by Pilbara Iron (Rio Tinto). Access to The Solomon Project received state approval under Ministerial Statement 862 and federal approval under the EPBC Act (EPBC 2010/5567) in 2011. In addition to the Solomon project, expansion of mining to the west is proposed within the Western Hub Project area which contains approximately 10 ore bodies. Fortescue is also conducting drilling programmes to further delineate resources and iron ore reserves within tenements surrounding Solomon and in additional locations throughout the Pilbara. In addition to its wholly owned tenements, Fortescue is party to joint ventures and agreements with other tenement holders within the Pilbara region and is the manager of iron ore exploration operations upon these tenements. Appendix B. Data Flow Diagram Data Flow Diagram Waste Management Plan MS 721 Cloudbreak Waste Management Plan 45-PL-EN-0014 Cloudbreak Waste Disposal 204-03-EN-PP0002 Fluorescent and other Globes Recycling M-PR-EN-0011 Scrap Metal Recycling M-PR-EN-0016 Develop a Waste Management Program Port Battery Recycling M-PR-EN-0008 Christmas Creek Solomon Cardboard Recycling M-PR-EN-0009 Printer Cartridge Recycling M-PR-EN-0018 Used Earthmoving Equipment Tyre Disposal M-PR-EN-0022 Plastics Recycling M-PR-EN-0015 Paper Recycling M-PR-EN-0014 End Appendix C. Cross reference to Ministerial Requirements Ministerial Conditions and Commitments Directly Related to the Waste Management Plan Ministerial Statement and/or Regulatory Approval MS 721- Iron Ore & Infrastructure Project: Cloudbreak (No Beneficiation) Requirement or Issue How Objective(s) Met by this Plan Develop a Waste Management Plan. As part of the Waste Management Plan, implement a procurement policy which minimises waste generation. This Plan Implement the Waste Management Plan. Landfill registrations Landfill site must be designed and operated in accordance with the Environmental Protection (Rural Landfill) Regulations 2002. Section 6, Table 4, Actions 3.1, 3.3 and 3.4 Ministerial Conditions and Commitments Indirectly Related to Waste Management Plan Regulatory Instrument and Section Requirement or Issue How Objective(s) Met by this Plan MS 690- Iron Ore & Infrastructure Project: Port & North-South Railway (Stage A) To develop and implement a Hydrocarbon Management Plan / Oil & Chemical Spill Contingency Plan Section 6, Table 4, Action 3.2 MS 707- Iron Ore & Infrastructure Project: East-West Railway Lines & Mine Sites (Stage B) To develop and implement a Hydrocarbon Management Plan / Oil Spill Contingency Plan Section 6, Table 4, Action 3.2 Appendix D. Sustainable Packaging Guideline Templates APPENDIX C: Template to review a packaging system against the Sustainable Packaging Guidelines Company: FMGL Review reference: 2011 (1) Contact: Procurement Manager Contact details: Product / packaging description Product – Primary packaging – Secondary packaging – Tertiary packaging – Existing or new packaging? Photo Date: Existing People involved in the review Name Position Company Rationale for involvement Procurement Manager Logistics Manager Environmental Manager Summary Considerations Activities to undertake to improve sustainability of packaging format/category [e.g. Investigate opportunities to replace film with a single, lighter weight material OR a compostable biopolymer] Environmental benefits to come out of review [Add after the investigation has been completed, e.g. material reduction, increased recovery through home composting] Environmental impacts, risks and barriers [Add after investigation complete, e.g. impacts of the biopolymer during growing/manufacture] Template to record demonstrated implementation of SPG Demonstrated implementation of the guidelines Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) Minimise materials (source reduction) 1. Is the packaging necessary? 2. Has the package been designed to use the minimum amount of material necessary to suit the required level of functionality: ‐ Minimum number of separate layers? ‐ Minimum packaging weight? 3. Are there any options to further reduce materials? 4. What is the likely impact of these options on functionality, product protection and consumer safety? 5. Does the design of the package allow the product to be completely dispensed, i.e. to avoid product wastage? Maximise water and energy efficiency 6. Have you and your suppliers taken steps to optimise the energy efficiency of production processes and distribution? 7. Have you and your suppliers taken steps to optimise the water efficiency of production processes? Use recycled materials 9. What is the amount and percentage of recycled material? (Specify source, i.e. pre‐ or post‐consumer) 10. Could alternative formats or materials incorporate recycled material or offer a better environmental impact solution? If so, how much, and why were they not selected? Demonstrated implementation of the guidelines Consumer packaging 11. Is it possible to use more post‐consumer recycled Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) material? If no, please explain the rationale. 12. Have you discussed the use of recycled materials with your marketing department and identified any market concerns? 13. If a recycled content claim is made, is the minimum level of recycled content specified in accordance with AS/NZS 14021? Use renewable and/or recyclable materials 14. What is the potential for and availability of materials derived from a renewable source? 15. Are the renewable raw materials grown and harvested using sustainable farming or forestry practices? 16. What is the potential for incorporating recyclable materials? 17. Describe your understanding on the extent to which the consumer packaging used is collected for recycling in the geographic area(s) where the product will be sold? Minimise hazards associated with potentially toxic and hazardous materials 18. Have you applied conventional and conservative risk management principles in the selection of substances for packaging applications (e.g. inks, pigments, stabilisers and adhesives)? This includes, where possible, elimination of toxic and hazardous substances or minimisation of such substances where their use is necessary. Demonstrated implementation of the guidelines 19. Does the packaging meet Australian and /or Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) international standards in relation to the levels of potentially toxic and harmful substances? For example, the EU Packaging Directive specifies that the combined weight of heavy metals (mercury, lead, cadmium and hexavalent chromium) in a package or any of its components must not exceed 100ppm. Use materials from responsible suppliers 20. Are your raw materials sourced from suppliers who have documented environmental management systems? 21. Do you give preference to suppliers that are signatories (if applicable) to the Covenant. 22. Are you or your suppliers engaged in a sustainability program such as the PACIA / EPA Victoria Sustainability Leadership Framework? Design for transport 23. Can the distribution packaging be reduced or eliminated through redesign of the primary or secondary package, or vice versa? 24. Are you currently using shelf ready/retail ready packaging? Is it being used effectively? If it is not being used effectively has this been communicated to others in the supply chain 25. Have you used light weighting (source reduction) strategies in your package design? Have you considered the overall environmental impact of light‐ weighting, e.g. does your design for transport have a Demonstrated implementation of the guidelines Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) negative impact on the recyclability of the used packaging? 26. Have you designed your consumer packaging to maximise the efficiency of secondary or tertiary packaging, e.g. for example in pallet configuration? 27. Are you fully utilising the transport options such as pallet efficiency and truck height? Are there any efficiencies that can be achieved? 28. Is there an opportunity to switch to more efficient vehicles, hybrid vehicles or renewable energy sources for your distribution fleet? 29. Do you consider back‐loading of used packaging or waste products once deliveries have been made? Can your distribution network aid the recovery of used packaging? Design for reuse 30. Have you considered and compared the environmental benefits of reusable packaging with single‐use packaging? 31. Do you have packaging supply chain confirmation that the package is capable of reuse for the intended application under normal conditions, without risk to the product or to the health and safety of packaging supply chain workers and consumers? 32. Has the product been designed to maximise the number of return trips / reuse? 33. Is the packaging format applicable for reconditioning once the packaging has fulfilled its Demonstrated implementation of the guidelines Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) designated purpose? If the product cannot be reconditioned, can the reusable packaging be recycled? Design for recovery 34. To what extent are the packaging materials collected for recycling in the geographic area in which the product will be sold? 35. How much of the packaging is recyclable? 36. How many materials are being used in this package? If more than one material is used, are the different materials compatible in the recycling process? 37. Are any materials bonded together and therefore difficult to recycle? If yes, has an alternative format/system been considered? 38. Has the packaging been designed to minimise the impacts that any components such as closures, labels, sleeves, carry handles, etc. may have on the recycling process? 39. Have you consulted with recyclers or composters (depending on the intended recovery process) to find out whether any components will be problematic in the recovery process or in the end‐product? 40. If compostable materials are being considered, has reference been made to industry standards such as the PACIA’s document, Using Degradable Plastics in Australia – A product stewardship guide and commitment? Demonstrated implementation of the guidelines 41. Is packaging of this type and purpose included in Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) the Australian Council of Recyclers (ACOR) Kerbside recycling specifications? Have these specifications been considered in the packaging design? 42. Have you developed and implemented appropriate labelling on packaging to encourage consumers to recycle or compost? 43. Is rigid plastic packaging labelled with PACIA’s plastics identification code? Design for litter reduction 44. Do you understand where, when and how the product will be used and by whom? 45. Is the package likely to be consumed away from home and therefore have the propensity to become litter? 46. To what extent is this packaging type represented in the litter stream? 47. How many separate or easily separable components that could end up as litter does the packaging item have (e.g., screw cap lids, peel off seals), and can they be reduced? 48. Has the package been designed to minimise the number of separate or separable components? 49. Do you provide advice for consumers on the label to encourage appropriate disposal or recovery? 50. What steps have you undertaken to reduce the occurrence of your packaging in the litter stream? 51. Have options been considered for away‐from‐ Demonstrated implementation of the guidelines Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) home recycling as part of an overall littering abatement program? Design for consumer accessibility 52. Has the consumer’s ability to access the product within the packaging been adequately considered in the design process? For example, has a consumer specialist analysed the actions required to interact with the product? 53. Have you considered whether the level of information on the packaging ensures the consumer is aware of its contents and how to open the package? 54. Have you considered the demographic of the consumer who will use the product? Are there any limiting factors typically associated with these consumers? 55. Can changes be made to improve the ability of the consumer to use the product without compromising the safety, security or quality? 56. To what extent has your company ever received any complaints in relation to accessibility of packaging? 57. Could an alternative design be used efficiently to minimise the requirement for tools such as a knife or scissors? Provide consumer information on sustainability 58. What environmental issues have been considered during development of the product’s marketing strategy, for example use of environmental claims, Demonstrated implementation of the guidelines Consumer packaging Secondary packaging Tertiary (used to bundle Opportunities for Evidence for (used to bundle secondary packaging, improvement auditors consumer product, e.g. e.g. pallet wrap, shipper, shrink film) strapping) logos and consumer education? 59. Will any environmental claims be made about the packaging item? 60. Has information been used on packaging to encourage recycling, for example the Mobius loop (refer to AS/NZS 14021). 61. Has plastic packaging been identified with the voluntary Plastics Identification Code which marks plastic containers to identify the plastic resin from which they are made? (Note ‐ The code is not intended to be a guarantee of recycling or to provide companies with a platform for environmental claims. Copies of the Code and Guidelines on its use are available from PACIA). 62. Has appropriate information in relation to litter prevention been included on all packaging of products likely to be consumed away from home? 63. If recycling logos are to be used on the packaging, have you identified existing systems that will be able to recycle the packaging? Appendix D Reporting Guidelines Reporting Guidelines Landfill Waste Volume Recording General waste volumes are determined from the landfill facility. When a new trench is excavated, the responsible person must: Record the date the trench was dug; date it was open for use; approximate length, width and depth of the trench; Request the Survey Team to obtain GPS coordinates of the extent of the new trench and the trench dimensions. This information can then be used to determine the volume of waste that will fill the trench, minus 1 metre of fill that will be used as cover. This determined waste volume can then be recorded into BMS. The data must also be entered into the appropriate Monthly Waste & Recycling Report. The Environmental Technician is responsible for monitoring the current landfill trench until it is full and record the date the trench is full and ready to be closed. Monthly Reporting The recycling contractors are required to submit a report to the chosen responsible person detailing the weights and/or volumes of recyclable materials received from Fortescue during the month. The responsible person must ensure all reports are received within 2 weeks after the end of the month. Data must be entered in the appropriate Monthly Waste & Recycling Report. The volume reports received from the contractors can then be reconciled with a waste & recycling monitoring spreadsheet to ensure the accuracy of the data. Annual Reporting All recycling and landfill data collected throughout the year will be consolidated and publically reported in the Annual Environment Report.
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