Holcim Directive on OH&S

PREPARATION AND USAGE OF ALTERNATIVE FUELS AND RAW

MATERIALS (AFR)

1. Basis
• Holcim Group Occupational Health & Safety (OH&S) Policy, 2007
• Management Handbook for Occupational Health & Safety of Holcim Ltd 2003
• Holcim Contractor Control Minimum OH&S Requirements 2005
• Holcim Fatality Prevention Elements 2007-2008
• Holcim AFR Policy, 2006
• Holcim AFR OH&S Manual, 2002
• Holcim AFR Quality Control Manual, 2004
• Holcim Standard Design Criteria, 2008
• Holcim Corporate Engineering Design Specification for Waste/AFR Facilities, 2005
• Holcim Integrated Management System Audit for AFR Platforms, 2006
• Holcim OH&S AFR Screening Audit, 2002
• Holcim-GTZ Guidelines on Co-processing Waste Materials in Cement Production 2006
• ISO 14001
• ISO 9001

2. Approval
This directive was approved by the Holcim Executive Committee on 27 March 2008.

3. Validity
This directive shall come into force on 1 April 2008.

4. Replacement
This Directive replaces the Holcim AFR OH&S Manual of 2002 which has now been
reclassified as recommendations.
Directive on OH&S

Alternative Fuels and Raw

Materials (AFR)

Table of Contents for the AFR OH&S Directive

1. Context
2. Purpose
3. Minimum Standard
4. Scope
5. Responsibilities
5.1. Responsibility of Group Company
5.2. Responsibility of Corporate OH&S
5.3. Responsibility of Corporate Industrial Ecology
5.4. Responsibility of Cement Manufacturing Services
6. Risk Assessment and Mitigation
6.1. Identification
6.2. Risk Assessment for Waste Acceptance
6.3. Action Plan and Monitoring
7. Legal Requirements
7.1. Absence of Local Legal Requirements
7.2. Local Legal Requirements Exist
8. Managing OH&S Aspects along the AFR value chain
8.1. General Principles
8.2. Waste Pre-qualification
8.3. Waste Collection And Transport
8.4. Waste Receipt and Storage
8.5. On-site Pre-processing
8.6. Processed AFR Transport (from pre-processing facility to co-processing facility)
8.7. Co-processing
8.8. Disposal
9. AFR Management Support Activities
9.1. Facility Design
9.2. Initial Commissioning
9.3. Laboratory Facilities
9.4. Maintenance
10. Miscellaneous
10.1. Archiving
10.2. Auditing
10.3. Human Resources
10.4. Flow Chart
11. Glossary of Terms
12. References
13. Annexes
13.1. Annex 1.
13.1.1.1. Diagram 1. Value Chain
13.1.2. Diagram 2. OH&S Control and Multiple Control Points (MCP)
13.2. Annex 2. Management of Alternative Fuels and Raw Materials (AFR) –Schematic
Process
13.3. Annex 3. Risk Acceptance/ Risk Evaluation

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Directive on OH&S

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1.0 Context:
The use of Alternative Fuels and Raw Materials (AFR) is an integral part of the Sustainable Development
concept of the Holcim Group. AFR constitute many different products utilized at Holcim facilities worldwide.
Because AFR may consist of hazardous wastes or materials, specialized procedures are required. The AFR
business involves specific hazard evaluation and risk management, and, potentially, liability of Holcim.
Proper control of these risks along the “waste to AFR value chain” (Appendix 1), and of the associated
potential liability, is essential to the continued use of AFR and other alternative resources in the production of
clinker, cement, asphalt, concrete, or energy co-generation. This Directive is intended to identify
requirements and procedures to be applied in the acceptance, handling, storage, pre-processing and co-
processing of AFR for the above mentioned activities in order to not harm people and minimize any potential
liability.
2.0 Purpose:
The purpose of this Directive is to:

• define measures to reduce safety and health risks related to acceptance, transport, storage, pre-
processing, co-processing, and disposal of AFR or waste-containing materials in Group Companies
to a level that is as low as is reasonably practicable;

• establish criteria to enable proper management of AFR related activities;

• establish criteria to assist Group Companies in complying with the Holcim OH&S and Holcim AFR
Policy;

• mandate that each Group Company has, and updates, an AFR Register of risks; and,

• establish that management of wastes/AFR can be audited per Annex 1 and Annex 3.
3.0 Minimum Standard:
This Directive, which may be amended from time to time, provides a minimum standard of mandatory
elements with respect to the management of the “waste to AFR value chain.”

Should the content of this Directive not comply with local legal and/or regulatory requirements ("Legal
Requirements") for an individual facility, the applicable local Legal Requirements shall prevail, but only to the
extent that such Legal Requirements are not less stringent than the minimum standards of this Directive.

4.0 Scope:
The scope of this Directive is world-wide and is applicable to all Group Companies’ and joint venture (see
clause 8.1 below) activities in the “waste to AFR value chain.”

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5.0 Responsibilities Accountable*

* (adapt according to local
organization)

5.1 Responsibility of Group Company

• It is the responsibility of each Group Company active in the “waste to AFR Local CEO,
value chain” to implement this Directive.
• To put in place structures, procedures/work instructions and resources Local AFR
(human and financial) which enable the implementation of and compliance Director/Manager,
with this Directive Local Technical
• To name a qualified person to support the communication, implementation, Director
compliance reporting and sustainability of this Directive

5.2 Responsibility of Corporate OH&S

Head of Corp OH&S
It is the responsibility of Corporate OH&S to:

• update this Directive;

• train and instruct those qualified persons (as per clause 5.1) regularly;

• provide, review and validate a list of approved specialized companies used

Regional OH&S
by Group Companies (e.g., engineering, industrial hygiene, chemical
Consultants
analysis) to support the implementation of this Directive;
• monitor compliance of Group Companies with this Directive.

5.3 Responsibility of Corporate Industrial Ecology

Head of CIE
It is the responsibility of Corporate Industrial Ecology to:
Head of AFR.BD
• provide input for future updates of this Directive;

• assure that the Directive is integrated into the “waste to AFR value chain” Head of AFR-BD
business model;

• train its consultants on the content of this Directive and its implementation;
• coordinate periodic independent process audits for Holcim AFR operations; Manager AFR
Process Audit
• provide standard tools and procedures to Group Companies;
• ensure that systems are in place which evaluate and review AFR
toxicological information and its communication to the appropriate persons;
• provide competency reviews e.g. waste chemistry (see clause 8.2).

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5.4 Responsibility of Cement Manufacturing Services

Head CMS
It is the responsibility of Cement Manufacturing Services to:

• train its consultants involved with AFR with regard to the contents of this
Directive;

• provide inputs for future updates of this Directive; Head of MPT

• update on a periodic basis the Design Specification for Waste/AFR

Facilities; and,

• provide training and auditing of the requirements of the Design Specification

for Waste/AFR Facilities;

• advise Corporate OH&S and Corporate Industrial Ecology on design

improvements regarding all aspects of the AFR operations.

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6.0 Risk Assessment and Mitigation

The goal of the risk assessment process is to anticipate and appropriately address
Local CEO and Local
potential adverse OH&S effects related to the use of waste and secondary materials
AFR Director/Manager
in the pre-processing of waste and co-processing and production of AFR.

The risk assessment process must identify and address potential OH&S risks as
close as possible to the point where the waste and secondary materials are
generated, minimally to the first tier of the Group Company value chain. [Refer to
the Holcim OH&S Management Handbook].The risk assessment process must be
carried out by a multi-disciplinary team.

Note: A multi-disciplinary team could include the following stakeholders: operators,

maintenance staff, laboratory personnel, process performance engineers, health
and safety specialists, environmental specialists, and medical specialists.

The outcome of the risk assessment process shall determine:

• whether the waste can be accepted “as is” (current state/as generated);

• whether the waste can/should be processed or modified at the source prior

to acceptance;

• what incompatibilities may exist with respect to other waste;

• whether modification of the plant proposing to use AFR will be required in

order to accept and utilize the waste;

• what additional information about the waste is required; or whether the

waste should be rejected;

• what waste acceptance criteria must be developed and documented;

• what sampling procedure for the waste must be developed;

• the risk assessment must specify the type and specification of personal
protective equipment (PPE) needed for employees and contractor
personnel, and for exposure monitoring and health surveillance;

• the risk assessment must review the adequacy of emergency response

procedures and equipment for transport to the Group Company waste
collection facility, as well as the storage and handling of the waste at the
Group Company site; and,

• the risk assessment must specify the level of security required of personnel
who shall handle the waste (e.g., fiscal/bonded waste).

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6.1 Identification
The Group Company shall take the steps necessary to identify and categorize
Local AFR Manager,
accepted wastes; methods for their transport, handling and storage; material flow
Co-processing Site
rates, processing and testing; along the “waste to AFR value chain”. (List of Manager
activities)
6.2 Risk Assessment for Waste Acceptance
Annex 3 must be used to perform a risk categorization for the acceptance and
Local CEO
handling of wastes to be used for AFR. Risk categorization records must be
maintained and used to determine specifications and safe working procedures. The Local AFR
list of activities must be used to perform the risk assessments and establish the Director/Manager
register of risks/catalogue. Whether such materials are present intermittently,
occasionally, or on a continuous basis, the related risks must be assessed. Re- Local Technical
evaluation of these risks must be conducted if significant changes occur. The Group Director
Company shall perform a health and safety risk assessment and shall establish a
Register of risks. The risk assessment (and Register of risks) must address the
potential health and safety risks, including process safety risks. For materials in
Quadrant 1 of Annex 3, the risk assessment must include a detailed Process
Hazard Analysis (PHA). Additionally an external audit must be provided to ensure
that the requirements of this Directive are fulfilled (see clause 10.2)

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6.3 Action Plan and Monitoring

An action plan, based upon the risk assessment and Register of risks, is to be
Local CEO, Local
developed and communicated to affected persons and is to include:
AFR Director
/Manager, Local
• Risk reduction actions; Technical Director
• Monitoring the integrity of plant/equipment used for storage, handling, and
use of waste or AFR;

• Monitoring of potential for personal exposure to AFR (Industrial Hygiene) Local OH&S
and protection of worker health (Medical Monitoring); and Manager

• Monitoring of compliance with established working procedures.

This action plan must be reported to the Local CEO and Corp OH&S. Local AFR Manager,
Local Technical
Director

Procedures and work instructions shall be reviewed for AFR specific risk activities
and rewritten to address these identified risks. Local CEO ,
Local AFR Manager,
Local Technical
Director

7.0 Legal Requirements

7.1 Absence of Local Legal Requirements

If the Group Company is using an external service provider (Contract Partner) for Local AFR
any of the services along the “waste to AFR chain”, such company must comply Director/Manager
with this Directive and the Holcim Contractor Management Directive.
Contract partners must provide OH&S with relevant information of wastes/AFR
Local AFR
generated, processes used, and how these materials are stored and handled.
Director/Manager
Holcim personnel must have the opportunity to verify such information. If this
information is not available, then site visits and representative samples must be
obtained by Holcim personnel and analyzed prior to commencement of work.
The Group Company shall keep records of Waste Generators, Brokers and Local AFR
Collector Companies, concerning waste quantities and types, frequency of Director/Manager
operations, and a review of performance and safety incidents.

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7.2 Local Legal Requirements Exist

If the Group Company is using an external service provider “Contract Partner” for
Local AFR
any of the services along the “waste to AFR chain”, such company must comply
Director/Manager
with local legislation, this Directive and the Holcim Contractor Management
Directive.

If the local Legal Requirements are less stringent than the Holcim Contractor
Management Directive, the latter shall prevail.
Contract partners must provide full disclosure of materials generated, processes
Local AFR
used, and material storage and handling procedures with regard to OH&S. Holcim
Director/Manager
personnel must have the opportunity to observe these procedures to ensure
compliance with the requirements of this Directive.

If, during the execution of an existing [long-term] contract, an instance of non-

compliance with the Directive is noted, then mitigation of the hazard must take place
in accordance with the level of risk.

If the risk is found to be unacceptable, shipments shall be terminated

8.0 Managing OH&S Aspects along the AFR value chain

8.1 General Principles

The following guiding principles shall apply:
Local AFR
Director/Manager
• Group Company must manage risks via the hierarchy of controls;
Local CEO,
• Industrial hygiene programs and medical monitoring programs must be in Local AFR
place; Director/Manager

• Group Company must ensure that the Directive is applied in any joint
venture;

• Group Company must ensure that appropriate tests/trials are undertaken

with the same level of safety as is required for permanent operations;
Local CEO, Local
• Intentional circumvention of the requirements of this Directive by any Holcim Human Resources
company employee shall lead to disciplinary review which may lead to Manager, Local
termination; Corporate Legal

• All Group Companies presently involved with AFR including those already
branded “Geocycle” must demonstrate compliance via external audits within Corp OH&S
two years of the issue of this Directive (see clause 10.2);

• Any Group Company planning to start AFR activities must comply with this Local CEO,
Directive before commencing. Local AFR
Director/Manager

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8.2 Waste Pre-qualification

The AFR Commercial Department shall:
Local AFR
• Understand the Holcim “negative list” of unacceptable waste materials for Director/Manager
co-processing;

• Understand the limitations of the particular Holcim AFR facility in terms of

waste pre-qualification, acceptance and or process limitations;

• Obtain relevant process information from the waste generator (contract

partner) regarding conditions of generation of the waste under
consideration;

• Visit and inspect the site where the waste shall be generated and/or stored
to determine if additional support will be needed to pre-qualify the waste or
contract partner;

• Collect representative samples at the initiation of the pre-qualification

process from the waste generator to verify compliance with pre-qualification
criteria;

• Undertake audits of waste generation and handling practices employed by

potential contract partners; and,

• Not transport waste to a Holcim facility prior to completion of the pre-

qualification procedure.

Failure to successfully complete these requirements shall preclude pre-qualification

Local AFR
of a waste material by Holcim companies
Director/Manager

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Competencies must be established for all personnel involved in waste identification.

Local AFR
These competencies must address knowledge of the following topics:
Director/Manager
• Waste chemistry

• Health and safety

• Environment

• AFR pre-processing

• AFR co-processing and its impact on production and quality

• Applicable permit conditions/local legislation

To ensure that these competencies exist and are maintained, mandatory training
and re-training must be provided by the Group Company.

• Prior to using a new type of waste or waste sources from a new generator,
Local AFR
a risk assessment must be undertaken and documented (see clause 6). Directors/Manager

A procedure must be in place to ensure that the requirements of this clause of the
Local AFR
Directive have been satisfied.
Director/Manager
Co-processing Site
Manager

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8.3 Waste Collection and Transport

Group Companies are responsible for ensuring that:
Local AFR
Director/Manager
• the transporter is licensed to collect and transport the waste;

• the driver is licensed to collect and transport the waste; Co-process Site
Manager
• the relevant waste acceptance criteria are satisfied or, that waste is not
loaded;

• the waste is correctly labeled;

• the waste containers are in good condition and there are no visible
indications of potential hazards (e.g., elevated temperature, barrel
expansion, smoke, spillage, leaks);

• loading the waste onto the transport occurs in a manner that ensures that
only compatible materials are transported together;

• the transport vehicle is clean, fit for use, and all safety equipment is
operational and easily accessible;

• the transport vehicle is correctly placarded (e.g. NFPA Hazard Rhombus)

and identifiable (number plate);

• correct and complete documentation describing the load (e.g., manifest) is

carried with the vehicle at all times;

• suitable specific emergency response procedures and equipment are in

place (e.g., 24 hour emergency numbers);

• crisis management plan has been defined;

• logistics have been clearly defined for minimizing OH&S risks;

• all legal requirements for transport are fulfilled; and,

• prior to loading and transporting waste, the driver has received clearance
that the requirements of clause 8.3 of the Directive have been satisfied.

• This clause applies to all forms of transportation.

Where a Group company engages a contractor to collect the waste, then the
Local AFR
contract shall include terms that bind the contractor to the requirements of clause
Director/Manager
8.3.

Local Logistics
Manager

8.4 Waste Receipt and Storage

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Upon arrival at the Group Company waste acceptance facility, personnel shall
Local AFR
ensure that:
Operations Manager
• the relevant waste specific acceptance criteria are satisfied, or that waste is
not accepted;
Co-processing Site
Manager
• a procedure must be in place to deal with wastes which are not accepted
(e.g. quarantine area, legal requirements, notification etc.);

• the waste is correctly labeled for storage;

• transfer of the waste to site storage occurs in a manner which ensures that
only compatible materials are stored together;

• the storage area is correctly labeled;

• acceptance of the waste shall not cause maximum permitted storage levels
to be exceeded, (e.g., regulatory levels, containment capacities);

• the capability of the facility’s fire suppression system determines the

maximal volumes to be stored;

• storage times for hazardous wastes are minimized on the basis of “first in,
first out.”
Group Company shall be responsible for ensuring that:
Local AFR
Director/Manager
• site personnel have been trained with regard to the chemical properties of
the waste, the acceptance criteria, transference procedures, storage
requirements, and emergency procedures;
Co-processing Site
Manager
• suitable safety, monitoring, and emergency response equipment is available
and operational at all times;

• transfer to storage does not occur if the two previous criteria are not met;
and,

• waste integrity is assured via inspection of the storage areas, at a frequency

determined by assessment of the risks
A procedure must be in place to ensure that the requirements of this clause of the
Local AFR
Directive have been satisfied prior to unloading and storing of waste.
Operations Manager
Co-processing Site
Manager

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8.5 On-site Pre-processing

Group Company shall be responsible for ensuring that:
Local AFR
Director/Manager
• an appropriate sampling plan exists and is re-evaluated as new materials
come in
Co-processing Site
• appropriate sample archives exist, samples are properly labeled and Manager
retention times as defined in the Holcim AFR Quality Control Manual are
respected

• site personnel have been trained with regard to the chemical properties of
the waste, pre-processing procedures, and emergency procedures;

• suitable safety, monitoring, and emergency response equipment is available

and operational;

• incompatible materials are not mixed;

• bioactive compounds such as pharmaceuticals shall not be shredded;

• procedures are in place to effectively manage situations where incompatible

materials are inadvertently mixed;

• pre-processed materials are stored in designated locations; and,

• pre-processed materials are correctly labeled.

A procedure must be in place to ensure that the requirements of this clause of the
Co-processing Site
Directive have been satisfied
Manager

8.6 Processed AFR Transport (from pre-processing facility to co-processing

facility)
The transporter shall be responsible for ensuring that:
Local AFR
Director/Manager
• a logistics plan defined and adhered to;

• the AFR is correctly labeled;

• the transport vehicle is clean and fit for use, and all safety equipment is
operational;

• the transport vehicle is correctly placarded;

• correct documentation describing the load is carried with the vehicle;

• suitable specific emergency response procedures and equipment are in

place (e.g., 24 hour emergency numbers)

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Group Companies are responsible for ensuring that:

Local AFR
Director/Manager
• the transport organization is licensed to transport the AFR;

• the driver is licensed to collect and transport the AFR; and,

• the driver has been instructed with regard to the properties of the AFR,
loading/unloading , transport, and emergency procedures.
In those cases where a Group Company engages a contractor to transport the AFR,
Local AFR
the Group company must ensure the requirements of clause 8.6 of this Directive are
Director/Manager
followed.
A procedure must be in place to ensure that the requirements of this clause of the
Local AFR
Directive have been satisfied.
Director/Manager

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8.7 Co-processing
Group Companies shall be responsible for ensuring that:

• A procedure exists specifying the type, volumes and delivery rates of AFR Co-processing Site
waste to be co-processed. Manager

• site personnel involved in AFR have been instructed with regard to the
chemical properties of the AFR and the co-processing procedures, and are
trained in emergency procedures;

• those operational circumstances in which AFR cannot be used as feed are

specified;

• suitable process controls are in place to ensure that AFR can be safely co-
processed;

• emergency response equipment is available and operational, and;

• monitoring occurs in order to identify potential health and safety impacts

A procedure must be in place to ensure that the requirements of clause 8.7 of the
Co-processing Site
Directive are satisfied.
Manager

8.8 Disposal
Disposal of wastes, waste-contaminated materials, or unused waste or AFR, must
Local AFR
be in accordance with local, state, or national legislation, and must use nationally or
Director/Manager or
Holcim approved contractors and facilities. A certificate of safe disposal must be
obtained from the disposal facility. Co-processing Site
Manager
Third parties used by Group Companies for disposal activities must be prequalified
by Group Companies at a minimum according to ISO 14001 requirements
A procedure must be in place to ensure that the requirements of clause 8.8 of the
Local AFR
Directive have been satisfied.
Director/Manager
Local AFR
Commercial
Director/Manager

9.0 AFR Management Support Activities

9.1 Facility Design

Capital approval shall not occur unless a Preliminary Process Hazard Analysis
Local EXCO
(PHA) is included in the business case. Minimum safety standards, as defined in
the Holcim Corporate Engineering Design Specification for Waste/AFR Facilities,
Holcim Standard Design Criteria, AFR Quality Control Manual and Fatality
Prevention Elements must be incorporated into the business plan.

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Directive on OH&S

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The equipment and facility design used for waste handling must comply with the
Local AFR
minimum criteria specified in the Holcim Corporate Engineering Design
Director/Manager,
Specifications for Waste / AFR facilities. Key criteria include:
Local Technical
• Materials of construction must be compatible with waste to be handled; Director

• Facilities and equipment must be designed and constructed in accordance

with relevant international design standards;

• Monitoring equipment appropriate to the types of materials to be handled

(e.g., temperature, pressure, smoke detection) must be installed and
operational;

• Hazardous atmosphere zoning and compatible electrical equipment design

must explicitly be addressed;

• Fire detection and suppression appropriate to the volume and types of

materials to be handled (e.g., water, foam) must be installed, operational
and available at all times;

• Segregation and layout must be designed to prevent the spread and

interaction of materials in solid, liquid, or gaseous form;

• Labeling of pipelines, storage containers, storage areas, and other parts of

the facility must be compatible with Holcim Standard Design requirements;

• Access to and egress from enclosed spaces must be well marked and must
be guaranteed at all times;

• Ease of maintenance must be incorporated into the design;

• Ventilation which is adequate and protective for the overall facility and for
specific work areas must be installed and operational;

• Potential for secondary incidental (“knock-on”) effects to/from the

surrounding areas (e.g., traffic, ignition sources) must be considered
explicitly in facility design and operation;

• All design requirements of Holcim FPEs (“Fatality Prevention Elements”)

are applicable and should be addressed explicitly.

After the facility design is complete, but prior to construction, a review of the initial
Local AFR
PHA must be undertaken and documented.
Director/Manager or
Updated designs must be integrated into the construction. Co-processing Site
Manager

9.2 Facility Initial Commissioning

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Necessary process information must be available to all operators and maintenance

Local AFR
staff at the time that the facility is first commissioned. This requirement shall
Director/Manager
include, but shall not be limited to:
Co-processing Site
• Process flow diagrams Manager

• Piping and instrument drawings

• Equipment manuals

• Electrical diagrams

• Details of “as built” underground services

Facility operating elements, including emergency response procedures, emergency

Local AFR
response equipment, fire safety precautions and first aid procedures, must be
Operations
developed, documented, and inspected prior to facility commissioning.
Director/Manager
Co-processing Site
Manager
Operator training for all employees must occur prior to commissioning of the facility,
Local AFR
and plans for appropriate follow-up training for new employees or for new facility
Operations
processes must be in place.
Director/Manager
Co-processing Site
Manager
A “permit to work” system for hazardous work [see Holcim OH&S Management
Local AFR
Handbook] issued by the Group Company, and the associated training, must be in
Operations
place for all employees prior to commissioning of the facility.
Director/Manager
Co-processing Site
Manager
An “as-built” safety and operability review must be conducted by a multidisciplinary
Local AFR
team from Holcim or an experienced specialized company prior to commissioning.
Operations
Director/manager
Local Technical
Director
If existing facilities subsequently are to be used for handling different materials, the
Local AFR
Management of Changes requirement [see Holcim OH&S Management Handbook]
Operations
shall apply. This may necessitate another PHA following institution of the new
Director/Manager
processes or receipt of the new materials.
Local Technical
Director

9.3 Laboratory Facilities

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Laboratory analytical facilities (internal or external to the Group Company) must be

Local AFR
suitably certified [ISO 9001, ISO 17025, Good Laboratory Practice Standard or
Operations
Governmental] and staff capable of measuring and evaluating the AFR or waste
Director/Manager
against the acceptance criteria.
Local Technical
At a minimum, laboratory supervisory personnel must include a qualified chemist Director
with analytical and organic chemistry experience.
Co-processing Site
A procedure for formal sign-off of analytical results according to the acceptance Manager
criteria (legal, OH&S, quality, environmental, process) must be in place.
Co-processing Site
Laboratory Manager.
Prior to accepting samples for chemical and/or physical analysis, a risk assessment
Local AFR
of sample handling, analysis, and storage practices for the laboratory should be
Director/manager
undertaken and documented (e.g., containers used for sample archives, chain-of-
custody procedures). Local AFR
Operations
Director/manager
Co-processing Site
Manager
Sample handling and storage must be in accordance with the Holcim AFR Quality
Local AFR
Control Manual and Good Laboratory Practices.
Operations
Director/Manager
Local Technical
Director
Procedures and formats for communicating the outcomes of sample analyses to
Local AFR
responsible persons must be defined in advance.
Operations
Director/Manager
Co-processing Site
Laboratory Manager

9.4 Maintenance
A maintenance program must be established for all waste handling facilities, AFR
Local AFR
facilities, co-processing facilities and equipment. This program must demonstrate:
Operations
Director/Manager
• compliance with the requirements of the Holcim Occupational Health and
Safety Management system and Holcim FPEs; and, and
Co-processing Site
• focus on intersecting / overlapping activities within the facility. Manager

A procedure must be in place to ensure that the requirements of clause 9.4 of the
Local AFR
Directive are satisfied.
Operations Manager

Co-processing Site
Manager

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10.0 Miscellaneous

10.1 Archiving
Samples of waste/AFR materials should be archived based upon the
Local AFR
recommendations of the AFR Quality Control Manual.
Operations Manager
The Register of risks and all related reports and documents should be archived at a
Local AFR
central location on a project-by-project basis with the Group Company’s qualified
Director/Manager
person for at least 30 years
10.2 Auditing
Self-compliance reviews to evaluate whether the requirements of the AFR OH&S
Local AFR
Directive are being met must be undertaken at least annually in accordance with the
Director/Manager
Group Company internal review/audit plan.
Local Technical
Director
For each new high risk and high impact AFR waste stream shown in Quadrant 1
Local CEO
(see Annex 3), an external audit must be performed to ensure the requirements of
the AFR OH&S Directive are fulfilled. Local AFR
Director/Manager

External audits against the requirements of the AFR OH&S Directive shall be based
upon performance, but must occur, at a minimum, once every three years after the Corp OH&S Director
initial audit.

Group Companies which do not fulfill the requirements of this Directive shall define Regional OH&S
an improvement plan which shall be reviewed by OH&S personnel Consultant

10.3 Human Resources

Competency criteria must be established and assessed for all AFR-related roles.
Local Human
The remuneration schedule for personnel in AFR-related positions [indexed to
Resources Manager
chemical industry] shall be consistent with the qualifications, level of risk, and
responsibilities required of those positions.

A training master plan must exist with:

• Gap analysis of competencies
• Skills enrichment
• Personal development
• Succession planning
Group Company personnel responsibilities and accountabilities detailed in this
Local Human
Directive must be captured in the “Dialogue” process for that individual.
Resources Manager

10.4 Flow Chart

A description of the process of the management of AFR-containing materials in the
Corp OH&S
form of a flow chart is shown in Appendix 2.

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11.0 Glossary of Terms

Accountable/Accou The person who is responsible to someone or for some action/Answerable to

ntability someone for some action. The “Accountable” may delegate “responsibility” but
not “Accountability.”

Alternative Fuels See HARP

and Raw Materials
(AFR)
Business Case This Directive is intended to protect human health and safety by establishing
procedures that shall avoid loss of life and property, manage the liability of
Holcim and its clients, and protect the business reputation of Holcim.

Collector Own or third party site used to sort, classify and bulk waste materials suitable
for pre-processing. Materials not suitable for co-processing are sent for
recycling or disposal.

Contract Partner Contract Partner shall mean any international or national company properly
qualified (and certified and/or licensed, if applicable). Includes waste
generators, brokers, collectors, transporters, disposal companies.

Co-processing The recovery of energy and or minerals from AFR

Disposal The process whereby materials that have been accepted by a Group Company,
but which cannot be used for co-processing (e.g., residuals acquired under the
“total offer concept”), are sent to other approved third parties or facilities (e.g.,
landfill).

Group Company Consolidated company of the Holcim Group. see HARP

Local Referring to the Group Company/Operational Company level

Logistics The process of waste delivery to and from our sites, including AFR delivery
from our pre-processing sites to co-processing sites. Also includes direct
delivery to co-processing sites.

Multiple Control Critical control points in the “waste to AFR value chain”. Risk prioritization and
Points (MCP) management is essential to reducing transfer of liability.

NFPA National Fire Prevention Association

Pre-processing The process in which wastes or secondary materials are physically modified i.e.
size, shape, granulometry, heterogeneity to produce AFR.

Process hazard See Holcim OH&S Management Handbook

analysis (PHA)

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A health & safety record is a record of “evidence”. Once they are generated,
Records they cannot be changed or updated. Records provide evidence of the status of
the system at any given time.
It is essential that all Holcim operations have an effective records management
system. As a minimum, records need to be held for:
• Risk assessments (e.g. studies surveys, risk assessments etc);
• Health & safety training;
• Calibration and maintenance of monitoring equipment;
• Incidents, hazard reports, follow-up actions;
• Inspections (pre-operation, equipment, pre-commissioning)
• Task/safety observations
• Supplier and contractor information; and
• Health & safety audits.
Note: records are not subject to government document requests without
authorisation by Holcim legal counsel. The retention period for records
depends on local statutory, legal, and regulatory requirements but, at a
minimum, must be 30 years.

Recycling The collection of waste materials for the purpose of re-processing into primary
materials e.g. lead waste for battery manufacture, scrap iron for foundries

Regetox A risk screening program based upon the INRS “Simplified Methodology for
Chemical Risk Assessment.”

Responsible/Respo The party which is liable/The ability or authority to act or decide on one’s own
nsibility without supervision. The “Responsibility” may be delegated, but the
“Accountability” remains with the designated person.

Register of risks A collection of risks, their causes, controls, risk rankings, etc., associated with
all stages of the value chain. The Register of risks must address process safety
as well as occupational health and safety.

Storage Storage refers to retention of materials in designated locations, as well as

temporary retention on parked trucks, railcars, barges, etc.

Trial Acceptance, transport, storage, pre-processing, co-processing, or disposal of a

material for which no long-term decision regarding use has been made.

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12.0 References
The Council of the European Union. Council Directive 96/82/EC of December 1996 on the control of major-
accident hazards involving dangerous substances. Official Journal of the European Communities. No. L
10/13.

The European Parliament and the Council of the European Union. Directive 2003/105/EC of the European
Parliament and of the Council of 16 December 2003 amending Council Directive 96/82/EC on the control of
major-accident hazards involving dangerous substances. Official Journal of the European Union. L 345//97.

U.S. House of Representatives H.R. 5695. Chemical Facility Anti-Terrorism Act of 2006. A bill to amend the
Homeland Security Act of 2002 to provide for the regulation of certain chemical facilities, and for other
purposes. June 28, 2006.

Code of Federal Regulations. 6 CFR Part 27, Chemical Facility Anti-Terrorism Standards. April 9, 2007.

Code of Federal Regulations. 40 CFR Part 372, Toxic Chemical Release Reporting: Community Right-to-
Know. February 16, 1988

U.S. Code. Title 42, Chapter 116, Emergency Planning and Community Right-to-Know. October 17, 1986.
OSHA - 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals Standard.
American Petroleum Institute Recommended Practice 750: Management of Process Hazards. February
1990.
Center for Chemical Process Safety. Guidelines for Risk Based Process Safety. April 2007
Center for Chemical Process Safety. Guidelines for Implementing Process Safety Management Systems.
April 15, 1994
AS/NZS 4360:2004. Risk Management
AS/NZS4801:2001. Occupational Health and Safety Management Systems – Specification with Guidance for
Use

INRS. 2005 - Simplified Methodology for Chemical Risk Assessment: A decision making tool (in French) ND-
2233-200-05

13.0 Annexes

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