ENVIRONMENTAL MANAGEMENT PLAN

2019

Mpact Corrugated (Pty) Ltd

Done by: Frans !Gaoseb & Adolfine Indongo

Date: 2 July 2019

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ENVIRONMENT POLICY STATEMENT

2

Contents

1. Introduction ........................................................................................................................................... 3 2. Objectives of the EMP ........................................................................................................................ 3

3. Scope ..................................................................................................................................................... 4

4. Environmental Management System (EMS) ................................................................................... 4

4. Water Management ............................................................................................................................. 5

5. Land management ............................................................................................................................... 6 6. Air Quality Management ..................................................................................................................... 7

7. Waste Management ............................................................................................................................ 8

8. Resource Management .................................................................................................................... 10

9. Closure Plans ..................................................................................................................................... 11

10. Chemical Management ................................................................................................................... 12

11. Environmental Training and Awareness ...................................................................................... 14

12. Community Involvement ................................................................................................................. 14

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1. Introduction

Mpact Corrugated (Pty) Ltd is located in Walvis Bay in the Erongo Region of Namibia and is a carton manufacturing company that is both ISO 9001 (Quality Management System) and ISO 14 001(Environmental Management System) certified. The Operations that are undertaken at this site include corrugating, converting and printing. The organisation supplies cartons to the industrial, agricultural, meat, fish and beverage industries supplying more than 10 000 tons of packaging materials to customers per annum. More than 100 employees and contractors are employed at this company and it outsources processes related to Information Technology (IT), engineering, cleaning and security services. In order to produce the cartons various processes are followed as shown in Appendix 1. Two shifts work on the site, working from 06:00 – 16:00 and from 16:00 – 02:00 from Monday to Friday on a normal basis. The organisation is surrounded by the Dorob National Park. The municipal area (Walvis Bay) in which the organisation is located is however not included in this park and therefore the company is not subjected to restrictions applied to the National Park.

Mpact Corrugated (Pty) Ltd aim to support and protect the environment in which we operate.

Striving to cause as little damage to the environment as possible. The Environmental

Management Plan (EMP) addresses the management of the significant environmental impacts

related to the processes on site.

2. Objectives of the EMP

This document provides information on the mitigation measures designed to minimize or

eliminate the significant adverse impacts that may be caused by the site’s processes. The top

5 significant impacts derived through risk rating is as follows:

Aspects Impacts

Electricity usage at the Baler and the

Board Machine

Land, water & air pollution. Global warming (when fossil fuels are used for power generation)

Use of potable water for the Boiler,

ablution facilities and for drinking

Depletion of a natural resource.

Discharge of effluent water Eutrophication at the Municipal sewerage

site. (The impact is limited due to the fact

that less than 10% of the input water is

returned to the municipality. Water is

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treated at the effluent plant and re-used

for cleaning purpouses)

Generation of waste Land Pollution

Use of HFO at the Boiler Consumption of hydrocarbons, a non-

renewable resource.

Boiler Emissions Air pollution (Particulates, SO2, NOX, CO

& CO2)

Table 1

The primary objective of the EMP is to:

Describe actions taken for achieving the mitigation measures for the aspects/impacts,

Indicate responsibilities and frequencies of actions taken,

Legal compliance

3. Scope

This EMP (Environmental Management Plan) is applicable to the factory and the warehouse

located at 44 Third Street East, Walvis Bay.

4. Environmental Management System (EMS)

EMS is a structured framework for managing an organization’s

significant environmental impacts.

Mpact Corrugated is ISO 14 001:2015 certified by Bureau Veritas as part of a Divisional

Certificate. The ISO 14 001 certificate numbers is IND 16.6282 U/E.

The EMS is audited by both internal and external auditors against the ISO 14001:2015

standard and own procedures. This ensures the functionality of the EMS.

A non-conformance procedure is in place to handle environmental issues and involves

investigations into root causes and finding corrective actions.

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Management Review meetings are conducted twice a year to review the whole EMS. Daily

Kaizen meetings are held, providing a platform for discussing any environmental deviations

and solving them.

An annual training plan is set up so as to address the training needs of various departments

leading to a competent workforce and contributing towards a better management of the

environment.

An impacts/aspects register is available for various sections and reviewed on an annual basis.

The impacts of the aspects are classified as either high, medium or low based on a risk rating

that is a product of severity, frequency and exposure.

Objectives and Targets are set on an annual basis to address significant impacts.

An online legal register is available to the SHEQ Department, supervisors and managers.

Monthly updates are provided on changes in the Legislation that can affect the EMS.

4. Water Management

In 2011 a total of 7 927 m3 of water was used on the site compared to a projected total of 3

511 m3 in 2019 (calculated from the YTD June result of 1755 m3).

Projects as required by the ISO 14 001 standard are undertaken on an annual basis to reduce

water usage. Some of the projects undertaken in the last 3 years include the re-use of water

after treatment for cleaning activities at the Board Machine and to make starch batches that

are used in the manufacturing of cartons.

All effluent water used in the factory is channeled to the effluent plant which is contained

inside a bunded area. Sud-floc is used to treat the water up to acceptable levels. The treated

samples are send to Analab in Windhoek for analysis on a two monthly basis and the results

are compared against the Walvis Bay Municipal standards. An example of effluent results is

given in Appendix 2.

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To prevent water spills and the subsequent water pollution, the following measures are taken

Preventative maintenance on machinery and equipment

Employee training

Procedures for water management & for emergencies involving water spills

Spill Kits

Good housekeeping practices

The following activities are conducted on site on a periodic basis:

Activities / Objectives Targets Responsible

Person

1. Sampling and analysis of effluent water 1-2 months SHE

Coordinator

2. Recording water results in a database. This is

managed by the Municipality of Walvis Bay

Daily Municipality of

Walvis Bay

3. Treatment of effluent water at the effluent plant for

re-use or dispatch to the municipal sewers.

Daily to weekly Effluent

attendant

4. Setting targets for potable water consumption Annually Managers

Table 2

5. Land management

The land is primarily used for the manufacturing and converting of cartons. Some parts of the

land (Warehouse) are used to store paper reels and finished goods.

Measures are taken to prevent the contamination of the land above and below surface. An

Emergency preparedness and response procedure EMS OP 15 is available for the handling of

spillages of hazardous material, effluent and leaks and it also addresses fire emergencies.

Emergency teams have been appointed and relevant emergency numbers are placed on

notice boards. Fire escape signs are displayed in the factory and the warehouse with fire

fighting equipment placed at strategic points. Main Fire assembly points along with alternate

assembly points are available for various departments to meet and to conduct roll calls.

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Spill kits are available at various points to prevent the spread of a spilled substance and to

clean the contaminated area.

Most of the surfaces at Mpact where activities take place have a concrete/paved surface. In

the rare event that a hazardous chemical would spill on the soil, this soil will be removed as

quickly as possible and disposed of as hazardous waste.

Bunded walls are constructed for the following areas in order to contain spills:

• HFO tank area

• Effluent plant area

• Ink area.

Trenches are constructed at the waste storage area to contain any possible liquid waste,

although only solid waste is stored in this area.

Some other measures that assist with land management include the following:

Activities / Objectives Targets Responsible

Person

1. Cleaning of all areas Daily Cleaning Contractor

2. Removal of general waste As required Contractor

3. Removal of hazardous waste As required Contractor

4. Incineration of medical waste

(Municipal Landfill Site)

As required Clinic sister

5. Replace hazardous chemicals

with less hazardous ones.

As required SHEQ Department

Table 3

6. Air Quality Management

Mpact Corrugated strives to reduce air pollution by having annual targets on the use of fossil

fuels. The main fossil fuels used on site are HFO and LPG. The air emissions from the site are

directly proportional to the amount of fossil fuels used.

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The HFO and LPG usage is monitored on a monthly basis and is reported on a monthly basis

on the Mpact Database (Mpres) as well as in the local month-end reports. The principles of

continuous improvement as contained in the ISO 14 001 standard are applied on an annual

basis to reduce fossil fuel usage.

The following additional actions are taken to reduce air pollution:

Activities / Objectives Targets Responsible

Person

Service of the Boiler (includes calibration of the

conductivity probes, gauges & water level checks)

Monthly Maintenance

Foreman

Monitor the air quality emanating from the

Boiler stacks. Particles checked are: (O2, CO

& CO2)

Twice a

year

Contractor

Table 4

7. Waste Management

Waste separation is done at source. Waste stations are in each department with colour coded

wheelie bins and boxes. The separation of waste is done as follows:

Recyclable waste - Green wheelie bins. The bins are emptied in a skip collected by

Rent-a-drum for further recycling

Non-recyclable waste - Orange wheelie bins. The bins are emptied in a skip whose

contents are dumped at the general landfill site

Hazardous waste – Red wheelie bins. The final product end up at the municipal

incinerator or the hazardous landfill site

Metal waste – Black wheelie bins. Collected by the scrap metal dealer for further

recycling

Office paper – Collected in Slotted lid boxes. Baled on site and dispatched to Mpact Recycling (SA)

Cut off or waste cartons – Collected in metal cages. Baled on site and dispatched to Mpact Recycling (SA)

Electronic waste – Collected in Slotted lid boxes. E- Waste is given to Transworld

Cargo.

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Ink cartridges – Collected in Slotted lid boxes. Send to the municipal incinerator or

contractor for refilling.

Table 5 below gives an indication of the waste streams generated on site:

Principle Component of the waste stream

Waste Storage Area

Container Average monthly quantity generated

Duration of Storage

Classification (non-hazardous)

Disposal/ Resold/ Recycled/ sold as scrap

Chute waste (from extraction system of factory)

Outside Baler

None 101 tons 1 week non-hazardous

Recycled

Oil trench - in Area at waste skips

2.61m3 Waste Oil tank

0.87m3 6 months hazardous Recycled

Dies (these are separated into metal and wood)

Reel store None 1 <1 week hazardous Recycled

Stereos Reel store None 1 <1 week hazardous Disposal

Anvils Outside Baler

General waste Skip

2 <1 week hazardous Disposal

Reel ends (plastic stoppers)

Close to Corrugator

General waste Bin

97.7Kg <1 week non - hazardous

Recycled

Reel cores Close to Corrugator

Trolley 0.53 tons <1 week non - hazardous

Recycled

Shrink wrapping Next to conveyor system At Gate Control

General Waste Bin

1.41Kg <1 week non - hazardous

Recycled

Shrink wrapping cores Next to conveyor system At Gate Control

General Waste Bin

- <1 week non - hazardous

Recycled

Plastic strapping Where used at various Machines

General Waste Bin

292.56Kg Dependant on when max. Capacity is reached.

Non - hazardous

Disposal

Plastic strapping cores Where used and next to various units

General Waste Bin

- Dependant on when max. Capacity is reached.

non - hazardous

Sold

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PPE (gloves, breathing masks, ear plugs)

Where used in various Depts.

General Waste Bin

- Dependant on when max. Capacity is reached.

hazardous Disposal

Garden refuse (where applicable)

Removed Off - site by contractor

Plastic bags

on the spot Non - hazardous

Disposal

Building rubble Removed Off - site by contractor when generated

Asbestos (where applicable)

Removed Off - site by contractor when generated Hazardous Disposal

Effluent cake Removed Off - site by contractor when generated Non-hazardous

Disposal

Florescent tubes Removed Off - site by contractor when generated Hazardous Disposal

Table 5: Waste Streams on site

8. Resource Management

The management of natural resources is important in terms of sustainability. All raw materials

are used sustainably to ensure minimum wastage. The amount of natural resources used is

reported on a monthly basis on the internal reporting system. The main material inputs on site

include the following:

Paper

Starch

Water

Caustic Soda

Borax

Corwet

Glue

Ink (Water based)

HFO

LPG

Procedures are available and implemented for the manufacture of the starch mixture (starch,

water, caustic soda, borax and corwet) so as to prevent wastage.

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Software such as Shopware is used in the factory to monitor machine efficiency. The

efficiency of machinery is part of the key performance indicators of those working in the

factory including the General Manager. Improved efficiencies on the machine results in less

raw materials being used.

Paper waste is an important key performance indicator and is included in the performance

agreements of employees. The paper waste target for 2019 is 9% and the YTD June 2019

result is 8.9%.

9. Closure Plans

The need for accurate closure plans are an integral part of the Business. Some of the tasks to

be undertaken upon closure are specified in the table below:

Activities / Objectives Targets Responsible

Person

1. Form a committee for the closure project 3

months

before

closure

Management

2. Close out permits with the local municipality.

Applicable permits and renewal dates:

Business registration permit - 2020, Effluent

discharge permit - 2020, Flammable stores

permit - 2022, Waste removal permit - 2020.

Upon

Closure

SHEQ Department

3. Conduct a hazardous materials survey and

remove hazardous materials. These materials

include asbestos, lead, mercury, PCBs,

refrigerants, etc. Some of the potential sources of

hazardous material include building materials,

paint, switches, lights, ballasts, batteries,

transformers, and cooling systems.

3

months

before

closure

Qualified contractor

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4. Drain & Salvage the HFO and Boiler tanks.

The tanks will be sold to the scrap metal dealer.

Drained oil will be recycled.

Upon

Closure

Maintenance team

5. Evaluate the integrity of the wastewater

treatment plant tanks and chemical storage

containers. It will be scrapped and disposed of at

the appropriate landfill site. Chemicals used in

the wastewater treatment plant will be returned to

the supplier.

Upon

Closure

Maintenance team

6. Evaluate the structural integrity of the press

pits and process tanks associated with current

machinery. Remove for recycling or disposal.

Upon

Closure

Maintenance team

7. Inspect and drain the transformers. Test fluids

for PCB’s unless a record of prior testing and

certification is available.

Upon

Closure

Maintenance team

8. Return LPG cylinders to the supplier. Upon

Closure

Store man

9. Land rehabilitation – Consider options such as

the removal of possible contaminated soil, soil

washing, bioremediation, neutralization of the soil

, incineration of contaminated soil and

Containment of the polluted soil in cement or

other such materials if necessary. This is to

ensure that the land is safe for fauna and flora

and similar to surrounding undisturbed areas.

The rehabilitation should meet the standards as

set out by the local municipality.

Upon

closure

Specialist AIA.

Table 6

10. Chemical Management

Chemicals play a major role in everyday life. They are used extensively throughout Mpact Corrugated. Chemicals used on site include starch, caustic soda, borax, corwet, glue, ink, HFO, LPG and various oils and soaps.

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Major chemicals used on site are classified and labelled according to the United Nations Globally Harmonized System (GHS) and pictograms are provided to highlight the hazards. The Material Safety Data Sheets (MSDS) of chemicals are kept in files in the SHEQ

Department and is also presented at the relevant areas where chemicals are used.

Training is provided to employees who handle chemicals and this includes the use of MSDS

and handling of emergency situations involving the inhalation or ingestion of chemicals.

Only chemicals that are compatible are stored together, so as to prevent unwanted chemical

reactions.

Flammable chemicals such as oils and paints are stored in a flammable store which can

contain more that the volume of chemicals stored in it and is well equipped with fire fighting

equipment.

An LPG room is available with the correct ventilation and signage for filling LPG cylinders

used by forklifts as a source of fuel.

Some of the activities undertaken to facilitate safe handling of chemicals are listed below:

Activities / Objectives Targets Responsible

Person

1 An MSDS is requested for all new chemicals

that are purchased.

As required SHEQ & Buyer

2. MSDS are kept in files and also put up at all

chemical storage points. Through inspections it

is checked if all MSDS are present

Weekly SHE Coordinator

3. Follow Procedure EMS OP 03 – Handling &

Storage of Dangerous Goods & Hazardous

Waste. This procedure addresses the loading &

unloading of dangerous goods as well as

storage and the handling of new chemicals

Continuously SHEQ Department

Table 7

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11. Environmental Training and Awareness

Environmental training and awareness is provided to all employees on an annual

basis and includes Induction training, Toolbox talks, Awareness campaigns, HR

training and SHEQ training. The SHEQ training matrix for 2019 in included in

Appendix 3 for ease of reference. Supervisors and managers are also provided with

training on handling of non-conformances and this includes the finding of root causes

& corrective actions.

12. Community Involvement

Mpact Corrugated is a member of the Recycle Namibia Forum and involved in projects

promoting the three R’s namely Reduce, Re-use & Recycle in Namibia. Mpact

Corrugated also participate in clean-up operations and conducted a beach clean-up

operation on 7 June 2019 in celebration of World Environment Day (5 June 2019).

Mpact has participated in other projects in the community such as the Garden project

at JP Brand School, Utuseb in 2017/2018. It also conducted Mathematics tutoring

classes at Kuisebmund Secondary School, De Duine Secondary School, and

Flamingo Primary School & West Side High during the period 2015 to 2018. It

continues to sponsor Cancer Namibia events and other initiatives in Namibia.

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Appendix 1: Process Flow

Mpact Corrugated Namibia Process Flow -

Quality

Receipt of raw materials - paper

Reels of paper delivered by truck

Offload reels using clamp truck

Place reels into warehouse on

dunage

Starch KitchenMixing a batch of

starch

BoilerStarting the boiler to generate steam

Manufacturing of Board by Corrugator

Transport reel to Corrugator

Place reel into position

Cardboard scored, slit, chopped to size

& stacked by machine

Transfer board onto pallet

Receiving of raw other materials

Converting

Stacked board transferred to palletizer or converting

by forklift

Board fed into printing machine

Print boards Die cut boards

Cartons bundled and strapped

Strapped bundles packed on pallets

Transfer stacked bundles to palletizer

by forklift

Pallets transferred

Raw materials: starch, glue, dies,

palstic……….Machine parts

Pallitizer

Warehouse \ Dispatch

Ship finished goods to customer

Glue cartons

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Appendix 2: Effluent sample analysis

To: Mpact Corrugated (Pty) LtdP.O. Box 399

Walvis Bay Date received: 29-May-19

0 Date required: 0-Jan-00

Date completed: 7-Jun-19

Attn: Mr F. Gaoseb

mail: fgaoseb@mpact.co.za Your Reference: PO 433340

Lab Reference: I190908

Sample details municipal effluent

Date of sampling 2019/05/28

Time of sampling 15:30

Test item number I190908/1

Parameter Value Units

p H 7.4 5.5-12

Conductivity 422 mS/m 450

Total dissolved solids (det.) 2401 0.94 mg/dm3

3000

Total suspended solids 30 mg/dm3

500

Chemical Oxygen Demand as O2 921 mg/dm3

1350

Sulphate as SO4 95 mg/dm3

300

Total phosphates as P 0.41 mg/dm3

30

Free & saline ammonium as N 100 mg/dm3

50

Chloride as Cl-

1175 mg/dm3

1500

Cyanide as CN-

<0.01 mg/dm3

2.5

Sulphide as S2-

<0.05 mg/dm3

10-50

Phenolic coumpounds as phenol 3.0 mg/dm3

Hexavalent chromium as Cr6+

<0.01 mg/dm3

0.5

Fat, oil and grease 4 mg/dm3

50

Sodium as Na 564 mg/dm3

1000

Iron as Fe 0.09 mg/dm3

10

Manganese as Mn 0.04 mg/dm3

5

Copper as Cu 0.01 mg/dm3

1

Zinc as Zn 0.03 mg/dm3

5

Boron as B 0.54 mg/dm3

5

Arsenic as As 0.01 mg/dm3

Selenium as Se 0.04 mg/dm3

5

Mercury as Hg <0.01 mg/dm3

0.005

Lead as Pb <0.01 mg/dm3

2

Cadmium as Cd <0.01 mg/dm3

0.5

Chromium as Cr <0.01 mg/dm3

Nickel as Ni 0.01 mg/dm3

4

Titanium as Ti 0.02 mg/dm3

Remark: * as supplied by client, valid from 1st January 2018

Current limit *

TEST REPORT

Municipality of Walvis Bay

Industrial effluent Standards

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Appendix 3: Training Matrix

Training Module Pro

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on

sta

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Main

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Dis

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Su

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iso

rs &

Man

ag

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Ad

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Vis

ito

rs t

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on

are

as/c

on

tracto

rs

All

vis

ito

rs

Fix

ed

Term

Co

ntr

acto

rs

Safety,Health,Environ

mental & Quality

Induction Feb-March Feb-March Feb-March Feb-March April - - Ad-hoc

Mpact - Safety Rules

to live by Feb-March Feb-March Feb-March Feb-March April - - -

MPSA Philosophy &

Principals Feb-March Feb-March Feb-March Feb-March April - - -

Safety meetings

(Toolbox talks) Monthly Monthly - - - - - -

Risk Assessment

Training July July July July - - - -

Forklift training Ad-hoc Ad-hoc Ad-hoc - - - - -

ISO 14 001

(Aspects/Impacts &

Emergency

Procedures) Oct Oct Oct Oct - - - -

Cartoons - Topic to

be decided April April April - - - - -

Cartoons - Topic to

be decided June June June - - - - -

PJO's Aug Aug Aug Aug - - - -

Sectional Induction

(show toilet, kitchen,

emergency assembly

points, dangers on

the machine) - - - - - Ad-hoc Ad-hoc Ad-hoc

Training presenters

Line Supervisor

Erastus Nakashona

External Trainers

Frans !Gaoseb

Adolfine Indongo

Erastus & Adolfine

J Dishena

SHEQ Team

Mpact Namibia - SHEQ Training Matrix 2019

Revision:

Doc no: EMS OR 13 Reviewed: F !Gaoseb

Owned by: HR Manager Effective Date: 01/01/2004