|The purpose of this document is to define the corporate
requirements that Transnet National Port Authority of South Africa (TNPA) places
on all the ports under its control. the contents of this guideline document are
based on both input from workshops held at several ports during the policy formulation
process, as well as environmental policy related literature representing best
practice internationally. |
Roles and Responsibilities
The management representative responsible for overall environmental
management is the TNPA General Manager, landlord services. functionally the responsibility
lies with the TNPA's Environmental Manager
At each Port the management
representative overall for the environmental system is the Port Manager. Functionally,
the responsibility lies with the Port Environmental Manager
In line with the TNPA's commitment to Incorporate environmental
management into its corporate governance initiatives TNPA will disclose its environmental
performance publicly in an annual Environmental report. The report will be compiled
in line with internationally recognised reporting guidelines such as that of the
Global Reporting Initiative. The Report will be verified by an independent third
Issues for inclusion in Port EMSS waste.
will develop holistic and integrated procedures for waste management, to manage
waste in a manner that complies with national legislation and with the principles
of good governance. TNPA will take such steps as arc reasonably within their control
or influence to ensure that waste management in ports, whether by shipping, terminal
operators, tenants or any other persons or to organisations using the ports, manage
their waste in accordance with this policy. Waste management procedures will address
pr the following specific aspects:
of consignment issues concerning waste
Ports will conduct an
inventory to determine who is producing waste, and the nature being produced.
Particular care will be taken to identify sources, types and quantities of hazardous
waste, and to ensure that such waste is disposed of in accordance with this policy.
and operators will be required to cooperate with the TNPA in this exercise, by
providing the data required for the to disclose is as follows
of wastes generated
- Amounts of each different types of waste generated
within a specific period and
- method of disposal.
TheTNPA shall approve the contractors used by those
under their control, or their reasonable influence, responsible for waste management
within port areas. Tenants and operators shall provide the following information
to the Relevant ports management for their approval, before a waste contractor
is licensed to operate inside the port:
- Name of contractor
of valid license or proof of registration
- Nature of waste that the
contractor will be handling
- Procedures for disposal of kinds of waste
that the contractor will be handling
- Location of waste disposal facility
that the contractor will use
Once approve, the contractor will
be issued a license to operate within the port. This license will not constitute
endorsement of the contractor by lie TNPA in any way, nor will it limit the rights
of the TNPA in any way to take action against the contractor should it contravene
the legislation pertaining to waste disposal
collection areas for ship waste
Clearly designated areas will
be located in each port, and equipped with skips or other appropriate containers,
to acceptance of general, domestic waste. The location of these areas will be
indicated by large yellow signs with words WASTE RECEPTION POINT FOR SHIP
GENERATED WASTE in English and appropriate foreign languages. Signs should
be of the same size and design in all ports.
The issue of ballast water discharge is generally regarded
internationally as a significant environmental issue. The primary concern revolves
around the potential for the introduction of alien marine organisms into the harbour
ecosystem. No specific legislation governs this issue in South Africa, although
it could be regarded as an issue controlled indirectly under the National Environmental
Management Act (NEMA). A pilot project investigating ballast water is currently
under way in the Port of Saldanha (MAP). Following the outcome of this study,
TNPA will determine an appropriate policy with regard to management of ballast
water in other ports.
Waste emanating from urban
Each port will enter into discussion with its relevant
local authority and other relevant role players to agree on a strategy to control
the pollution of the harbour waters by litter and other waste carried into the
harbour by storm water from the surrounding areas.
The most important issues impacting on air quality are
dust atmospheric emissions from tenant factories, and ship emissions. Ships are
prohibited from producing smoke within the port confines, although reasonable
amounts are tolerated during startup of engines and while getting under way.
where dust producing cargoes are handled must include dust management procedures
in their environmental management systems. These procedures could include some
or all of the following:
- Covering of dust-producing materials during
- Covering dust sources being stored within the port confines;
- Dust suppression by watering down;
- Paving of loading
- Avoidance of loading or off-loading of dust producing cargoes
during windy conditions.
Environmental impacts that can result from Ore Vessel
maintenance, especially at the quayside, include wind blowing of spray paint,
plates and other Ore Vessel parts falling into the harbour, other undesirable
materials or substances falling in the harbour water, and noise nuisance.
port authority shall appoint a designated person, for controlling quayside Ore
Vessel repairs. A ship's master shall obtain a permit from this designated person,
prior to commencement of such maintenance. This permit will he generated by the
environmental steering committee, in order to ensure uniformity between ports.
In general, only internal maintenance activities shall be allowed
at commercial berths. Painting and paint removal operations by grit blasting will
only be allowed in the dry dock
Dry and wet docks
main concern with the dry docks and the floating docks, revolves around the release
of pollutants into the harbour. Internationally, such ducks may be covered, and
dry Jocks are very carefully swept before being flooded.
- Ports will
institute appropriate procedures to ensure that undesirable materials or substances
from the dry or floating docks do not pollute the harbour water.
tanks inventory and mapping of storage tanks
With the cooperation
of tenants and terminal operators data on all storage tanks in each port will
be collected and mapped. above ground and below ground. Data to be collected on
each tank includes the following;
- Owner of the tank, and details of
the leaser if leased;
- Capacity of the tank and surrounding containment
- Nature of chemicals or substances stored and compliance with
permits in relation to which chemicals for which storage is authorized;
of the construction of the tank, e.g. materials used, whether double or single
- Age and physical condition of the tank;
schedule and records;
- Party responsible for maintenance;
the case of underground storage tanks, location of monitoring borehole/s. if any;
- In the case of flammable substances being stored, the nature of adjoining
- In cases where tanks fall under the Hazardous
Regulations, evidence of compliance or otherwise with the regulations.
for maintenance of storage tanks
Procedures will be compiled
at each port following consultation with the owners of the tanks, to ensure compliance
with national, provincial and local legislation. These procedures would include
some or all of the following, as appropriate;
- Installation and monitoring
of bore holes to monitor ground water pollution;
- Remediation measures
where ground water pollution is found to have taken place;
of perrnit for storage of different chemicals or substances to those originally
- Scheduling of maintenance and leak checks, for instance
- Leak detection and monitoring devices
of tanks and containment walls
- Emergency response procedures in place
on the part of the tank owner (or responsible parties, if different) and adequacy
of training of responsible staff.
of feeder pipelines
In some cases, the state of repair of feeder
and other pipe lines is a matter of concern. Owners of pipelines are to be required
to investigate conditions of their pipelines, and report their findings to the
TNPA. The owners must be required to consult an independent person or company
to carry out the investigation. The results will be sent by the consultant to
TNPA and to the owner of the pipeline at the same time. In cases where these pipelines
are associated with facilities governed by the Hazardous Installations Regulations,
this aspect is specifically required by law.
Where pipelines are found to
be damaged, or likely to be damaged due to poor condition, then the owner must
be required to take appropriate action.
preparedness and response
Each port shall have comprehensive
emergency response plans, to deal with all foreseeable environmental emergencies.
These plans will be compiled following a careful consideration of the environmental
implications of emergencies that could occur, and would include the following:
requirement for the Harbour Master to consider the environmental implications
when taking a decision under the port of safe haven principle, especially when
the Ore Vessel in distress is carrying a hazardous cargo
a risk assessment on areas that have a high potential for oil and/or contamination
to occur and map the areas.
- Maintaining adequately trained and equipped
emergency response teams to deal with accidental spills into the harbour or on
- Application of the polluter pays principle whereby
those responsible for the spill are held liable for the clean-up costs.
care to be taken to remediate the environmental impacts caused by the spill, especially
if natural ecosystems are affected.
- A requirement to report environmental
accidents and emergencies immediately they occur, to the port captain The report
to include the name and contact details of the observer/reporter, a description
of the accident or emergency, and details of the source (if discernable).
on mixing chemicals or allowing contact between incompatible chemicals, for instance
during loading or unloading.
- Requirement for tenants and others in
possession of hazardous chemicals to be in compliance with the International Safety
Guide for Oil Tankers and Terminals (ISGOTT) standards, including maintenance
of material safety data sheets (MSDSs) incorporating environmental data as well
as safety data.
Dredging must be undertaken in accordance with each ports dredging
plan and permit. Sediment quality is to be evaluated on an ongoing basis during
dredging, and dredged material disposed of in accordance with the requirements
of the London convention (1972).
Because of harbour security, ports often have areas of salt marsh, mangrove
forest, wetlands, dune fields or other important or marine eco system that are
locally, regionally or even nationally important. Each port will compile procedures
and management plans for the management of the important natural ecosystems within
its area of responsibility. These procedures and management plans will include
the following, as appropriate:
- Ecological inventories of plants. animals,
other biota and habitats, especially Red Data species and
important natural systems such as fish spawning grounds grounds or waterbird areas
- Liaison with the local nature conservation authorities and local
environmental interest groups
- Management actions required, e.g. fire
management (burning programme, fire breakers, culling, harvesting or restocking,
monitoring, management of invasive alien biota)
- Opportunities for
environmental education and appropriate environmental education programme and
- Prevention of encroachment by human activities, including
illegal informal settlement, poaching, etc.
- Features of archaeological
or cultural importance, and their preservation
- A policy and procedure
on angling and/or commercial fishing in the harbour, for instance a system of
licenses with no-go areas demarcated to keep anglers away from the
- Advising shipping, tenants and terminal operators
of the protected areas
strategic environmental planning
Each port will conduct a Strategic
Environmental Assessment (SEA), as part of its integrated port planning process,
to determine the optimum approach to environmental management at the strategic
level. The SEA shall be carried out in accordance with the guidance document for
SEA, published by the Department of Environmental Affairs and Tourism, and their
findings shall be used to inform the Strategic Integrated Port Plan.
The TNPA will ensure that all activities
scheduled in the EIA Regulations, are properly evaluated and not commenced before
the proper authorisation has been issued within its area of responsibility. Tenants
and terminal operators intending to carry out a scheduled activity will be required
in terms of their leas agreements, an operating license or other contractual instrument,
to inform the Port Authority of that intention at the outset of the application
process to the relevant environmental and automatically register the Port Authority
as an interested/affected party in the study.
of plans by the TNPA
Any plans for infrastructure development
of any nature, whether scheduled or not must be submitted to the relevant port
authority for approval first.
In cases where buildings and other structures
within the confines of the port are to be demolished, whether by the TNPA or by
any other body or organisation, a management plan is to be compiled to address
issues such as disposal of the derelict building material, prevention of pollution
and site rehabilitation.
No clearance of any site occupied by natural vegetation
is allowed except in accordance with an approved plan. following ecological and
archaeological investigation of the site.
Operations bunkering and fueling
The TNPA is directly responsible
for bunkering of its floating craft. However, it will require of the Port Operations
Division that procedures be compiled and implemented to ensure that bunkering
in general is carried out in such a way as to minimize the likelihood of spills
On-land fuelling facilities will be paved with a small bund
wall surrounding the facility, to contain spills during fuelling and prevent soil
and groundwater contamination.
Buildings and ground
An inventory shall be conducted of buildings that
contain asbestos, in order to ensure that the asbestos is not released during
maintenance or demolition. The TNPA shall, after obtaining specialist advice,
compile a list of approved herbicides, insecticides and other pesticides for use
in ports and the use of such chemicals not on the approved list shall be allowed
univ after a formal approval is granted. Non-chemical means of controlling pests,
such as use of raptors or bat-hotels shall be encouraged.
The relevant Port Authorities shall require terminal
operators and others handling cargo to compile procedures for approval by theTNPA,
for the prevention of spillages of cargo, especially cargo that would be a pollutant
if it were to fall into the harbour. Procedures will also be required to prevent
spilled cargo from entering the harbour water.
The relevant Port Authorities
will monitor terminal operators and others to ensure that they adhere to the procedures
with regards to the above.
Public access to Harbours
Each individual Port Authority will review the situation with
regard to public access to its port and, where it is deemed to be an issue of
concern, will review and alter as necessary the access control procedures and
It is however recognised that ports are interesting places for
the general public, and that opportunities exist for the public to benefit from
awareness programs, which will allow them to visit the ports under controlled
circumstances thus promoting the TNPAs public image.
of legal and other requirements
This will be dealt with centrally
by the TNPAs head office so far as national and provincial legislation is
concerned, by subscription to a reputable legal update service. Individual ports
will be updated by the TNPA's head office when such legislation is amended. The
TNPA's head office will also deal with overall other aspects such as requirements
imposed generally by Transnet and other stakeholders.
and targets environmental management programme
Each port authority
will set its own objectives and targets with due regard for the requirements of
ISO 14001, and will devise an appropriate environmental management programme in
order to achieve them. Both the objectives and targets, and the accompanying environmental
management programme, are to be ratified by the EXCO of the individual.
and operation of the EMS
The actual implementation of the EMS
is the responsibility of the individual Port Authorities
This is essential
in the following way:
- Determination of the roles and responsibilities
within the EMS.
- The structure of the FMS. within the existing Port
Authority Management structure, including lines of reporting.
environmental characteristics of key positions in the EMS, arid the competencies
required for such position, and the undertaking of a training needs analysis to
determine which competencies need to he developed.
- A general employee
environmental awareness programme, to develop awareness amongst employee and stakeholders
of the generic environmental issues associated with ports, the specific environmental
issues in the port in question, the benefit of responsible environmental management
- The format and content of the EMS documentation
should, so far, as is sensible, be uniform between ports, for ease for mutual
auditing. So far as is reasonable, the EMS documentation should be integrated
with existing Quality Management and Health & Safety systems.
control procedures can easily be standardized between ports as with Quality Management
control procedures should be closely on the issues in this policy guideline document,
together with unique operational issues that may exist at individual ports. Stipulations
on tenants and terminal operations should be incorporated into lease and operating
agreements, which should be uniform, so far as is appropriate, between ports.
requirements should be imposed on tenants and operators to pass on the requirements
of their lease or operating agreements, to subcontractors and other suppliers
of goods and services.
Monitoring and measurement
Each port will develop a comprehensive system of key environmental performance
indicators and appropriate monitoring strategies to monitor and measure them.
Such key environmental performance indicators may include::
- Number of environmental incidents or accidents
of specific milestones, for instance the storage tank inventory, followed by achievement
of milestones regarding legalization of illegal tanks (e.g. leaking
- Census figures for key plant or animal populations in protected
- Legal compliance (periodic of legal compliance is a specific
requirement of ISO 14001
A uniform methodology for addressing EMS non-conformities
and for the undertaking of audits will be agreed by the environmental steering
committee, for implementation in all ports. Record Keeping Every port develops
its own system for the safe retention of appropriate environmental records, in
accordance with clause 4.5.3 of the ISO 14001 standard.
EMS audit methodologies
and protocols should be common, so far as is appropriate, between ports, to facilitate
inter-putt benchmarking. (As a general principle, persons conducting an audit
should he independent of the system being audited. Hence, port environmental managers
should not audit their own systems).