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 TNPA Environmental Policy
 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

Environmental Reporting

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 party.

Issues for inclusion in Port EMSS waste.

Ports 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:

Identification 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.

Tenants 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

  1. Nature of wastes generated
  2. Amounts of each different types of waste generated within a specific period and
  3. method of disposal.

Waste contractors

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:

  1. Name of contractor
  2. Copy of valid license or proof of registration
  3. Nature of waste that the contractor will be handling
  4. Procedures for disposal of kinds of waste that the contractor will be handling
  5. 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

Waste 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.

Ballast water

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 storm water

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.

Air quality

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.

Ports 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:

  1. Covering of dust-producing materials during transport;
  2. Covering dust sources being stored within the port confines;
  3. Dust suppression by watering down;
  4. Paving of loading areas;
  5. Avoidance of loading or off-loading of dust producing cargoes during windy conditions.

Dockside maintenance and repairs

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.

  1. Each 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

The 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.

  1. Ports will institute appropriate procedures to ensure that undesirable materials or substances from the dry or floating docks do not pollute the harbour water.

Storage 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;

  1. Owner of the tank, and details of the leaser if leased;
  2. Capacity of the tank and surrounding containment area:
  3. Nature of chemicals or substances stored and compliance with permits in relation to which chemicals for which storage is authorized;
  4. Details of the construction of the tank, e.g. materials used, whether double or single sided, etc;
  5. Age and physical condition of the tank;
  6. Maintenance schedule and records;
  7. Party responsible for maintenance;
  8. In the case of underground storage tanks, location of monitoring borehole/s. if any;
  9. In the case of flammable substances being stored, the nature of adjoining premises;
  10. In cases where tanks fall under the Hazardous
  11. Installations Regulations, evidence of compliance or otherwise with the regulations.

Procedures 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;

  1. Installation and monitoring of bore holes to monitor ground water pollution;
  2. Remediation measures where ground water pollution is found to have taken place;
  3. Award of perrnit for storage of different chemicals or substances to those originally authorized;
  4. Scheduling of maintenance and leak checks, for instance pressure testing;
  5. Leak detection and monitoring devices
  6. Inspection of tanks and containment walls
  7. Emergency response procedures in place on the part of the tank owner (or responsible parties, if different) and adequacy of training of responsible staff.

Management 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.

Emergency 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:

  1. A 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
  2. Conduct a risk assessment on areas that have a high potential for oil and/or contamination to occur and map the areas.
  3. Maintaining adequately trained and equipped emergency response teams to deal with accidental spills into the harbour or on land.
  4. Application of the “polluter pays principle” whereby those responsible for the spill are held liable for the clean-up costs.
  5. Particular care to be taken to remediate the environmental impacts caused by the spill, especially if natural ecosystems are affected.
  6. 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).
  7. Prohibition on mixing chemicals or allowing contact between incompatible chemicals, for instance during loading or unloading.
  8. 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 port’s 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).

Managing biodiversity

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:

  1. Ecological inventories of plants. animals, other biota and habitats, especially “Red Data” species and
  2. ecologically important natural systems such as fish spawning grounds grounds or waterbird areas
  3. Liaison with the local nature conservation authorities and local environmental interest groups
  4. Management actions required, e.g. fire management (burning programme, fire breakers, culling, harvesting or restocking, monitoring, management of invasive alien biota)
  5. Opportunities for environmental education and appropriate environmental education programme and facilities
  6. Prevention of encroachment by human activities, including illegal informal settlement, poaching, etc.
  7. Features of archaeological or cultural importance, and their preservation
  8. 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 commercial areas;
  9. Advising shipping, tenants and terminal operators of the protected areas

Port development 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.

Environmental impact assessments

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.

Approval 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.

Port 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 mid leaks.

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 maintenance

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.

Cargo Handling

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 measures.

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 TNPA’s public image.

Determination of legal and other requirements

This will be dealt with centrally by the TNPA’s 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.

Objectives 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.

Implementation 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:

  1. Determination of the roles and responsibilities within the EMS.
  2. The structure of the FMS. within the existing Port Authority Management structure, including lines of reporting.
  3. The 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.
  4. 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 system requirements.
  5. 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.
  6. Document control procedures can easily be standardized between ports as with Quality Management Systems.

Operational Control

Operational 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.

Specific 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::

  1. Harbour water quality
  2. Number of environmental incidents or accidents
  3. Achievement of specific milestones, for instance the storage tank inventory, followed by achievement of milestones regarding ‘legalization” of illegal tanks (e.g. leaking tanks)
  4. Census figures for key plant or animal populations in protected areas
  5. Legal compliance (periodic of legal compliance is a specific requirement of ISO 14001

Checking and corrective action

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).

 WES-KUS Marine supports this policy

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