INTERNATIONAL CYANIDE MANAGEMENT CODE … · Global Ocean Supply Chain – Callao ... The Port of Tianjin is the largest man made sea port in mainland China and forms and important

INTERNATIONAL CYANIDE MANAGEMENT CODE

MERCANTIL COMMODITY S.A.C.

SUMMARY AUDIT REPORT CODIGO 20552423993

BASE TRANSPORTATION, CALLAO, LIMA,

PERU

VERSION 01. 1

FECHA 04/05/2016

In collaboration with:

MAY 2016| MERCANTIL COMMODITY

Lead Auditor Signature

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INTERNATIONAL CYANIDE

MANAGEMENT INSTITUTE

Cyanide Transportation Operations

Summary Audit Report

For The

International Cyanide Management Code and MERCANTIL COMMODITY S.A.C. – Global Ocean Supply Chain – Callao –

Lima – Peru

Verification Protocol

www.cyanidecode.org

May2016

LIMA, PERU LIMA, PERU

http://www.cyanidecode.org/



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TABLE OF CONTENTS

INTRODUCTION ................................................................................................................................... 4

1 TRANSPORT .............................................................................................................................. 10

1.1 TRANSPORT PRACTICE 1.1 ................................................................................................... 10 1.2 TRANSPORT PRACTICE 1.2 ................................................................................................... 13 1.3 TRANSPORT PRACTICE 1.3 ................................................................................................... 15 1.4 TRANSPORT PRACTICE 1.4 ................................................................................................... 17 1.5 TRANSPORT PRACTICE 1.5: .................................................................................................. 18 1.6 TRANSPORT PRACTICE 1.6: .................................................................................................. 19

2 INTERIM STORAGE .................................................................................................................. 21

2.1 TRANSPORT PRACTICE 2.1 ................................................................................................... 21

3 EMERGENCY RESPONSE: ...................................................................................................... 22

3.1 TRANSPORT PRACTICE 3.1: .................................................................................................. 22 3.2 TRANSPORT PRACTICE 3.2: .................................................................................................. 23 3.3 TRANSPORT PRACTICE 3.3: .................................................................................................. 24 3.4 TRANSPORT PRACTICE 3.4: .................................................................................................. 24 3.5 TRANSPORT PRACTICE 3.5: .................................................................................................. 25



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INTRODUCTION

Information on the audited operation

Name of Cyanide Transportation Facility: MERCANTIL COMMODITY S.A.C.

Name of Facility Owner: MERCANTIL COMMODITY S.A.C.

Name of Facility Operator: MERCANTIL COMMODITY S.A.C.

Name of Responsible Manager: Bruno Bellatin Gomez de la Torre

Address: Calle Santorin 243 Santiago de Surco

State/Province/Country: Lima/ Peru

Telephone: +51 618 1616 + Fax: ---

E-mail: [email protected]

Aspects of the location and description of the operation:

MERCANTIL Commodity S.A.C. (MERCANTIL) has traded sodium cyanide over 20 years. In the Peru, the

solid sodium cyanide briquettes are are imported from different factories around the world. The Global Ocean

Supply Chain is used for shipments from the Port of Tianjin and Quingdao (CHINA) by ocean carrier and

then arriving at the port of Callao they are transported by the company TRANSMERIDIAM to warehouse

CONTRANS, before being transported to stock "MERCANTIL" (ALMACENERA EL PACIFICO S.A.C.,

certified company) or mining customer by certified carriers. The results of the transport, warehouse and

barge audit and due diligence evaluations are contained in a separate report. This certification audit included

the following components.

Global Ocean Supply Chain – All global ocean moves of sodium cyanide that originate in the China and

those that originate at the Port of TIANJIN or QUINGDAO as part of the MERCANTIL Supply Chain are

within the scope of this certification audit. MERCANTIL processes used to manage the ocean transport of its

products were evaluated through interview, a review of process descriptions, company standards, policies,

shipping records, and due diligence records. The results of the due diligence evaluations of THREE (03)

ocean carriers are also contained within this report. The threee ocean carriers for which due diligence

investigations were performed are:

1. Nippon Yusen Kabushiki Kaisha (NYK)

2. Maersk Line Agency

3. Mediterranean Shipping Co. (MSC)

The Due Diligence Investigations were also conducted for Golder Associates in use at the time of the audit.

Records were sampled to confirm that MERCANTIL had either evaluated the ports specifically for cyanide

safety handling practices, or that the port had been previously approved and used by MERCANTIL for

hazardous material shipments. The ports listed on the following page are used by MERCANTIL for sodium

cyanide shipments to gold mine customers and were included in this certification audit.

Additionally, the company was evaluated TRANSMERIDIAM transport and storage company CONTRANS

located in Peru.


The NYK Group is a global logistics enterprise centered on various forms of marine transport incluiding

global logistics business and bulk energy transportation, cruises, terminal and harbor transport, shipping –

related services and real estate. NYK has ocean, land, and air transportation networks that extend across

the globe.



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The NYK Group has made adjustments to utilize its containership fleet more efficiently and respond to

surges in container-shipping demand following the Global recession in 2008. NYK is establishing a global

service-rpute network by creating alliances with other shipping companies to respond to the diversifying

needs of customers including the GA Alliance and G6 Alliance. The GA Alliance comprises NYK North

America, whereas the G6 Alliance includes the GA members in addition to Mitsui O.S.K. Lines, APL, and

Hyundai Merchant Marine to cover the trade between Asia and Europe in addition to the trade between Asia

and the East Coast to North America.

The NYK Group provides its customer with terminal and stevedoring services for containerships, pure car

carriers, and cruise ships at terminals in Japan, Asia, North America, Europe, and Australia.

NYK Group maintains global ISO 14001 Certification.

As mentioned in the Auditor Guidance for Use of Cyanide Transportation Verification Protocol (October

2009), General Guidance notes, consigners are not able to conduct inspections and checks on shipping

vessels due to Port safety and security issues.


MAERSK, headquartered in Copenhagen Denmark, operates a fleet of containers vessels with worldwide

shipping coverage. The fleet consists of approximately 590 container vessels with the capacity to handle

more than three millon 200 foot containers. Maersk operates a container booking and traking system called

the Global Customer Service System (GCSS). The system is also the management tool for handling the

dangerous goods cargo for the proper control of the stowage of hazardous cargo.

Maersk have previously required companies to provide evidence that their product packaging has been

approved by government regulators and tested in accordance with international Maritime Organization (IMO)

Dangerous Goods (DG) Code. Maersk have the right to refuse cargo if the packaging, container and/or

documentation are not acceptable to IMO DG Code standards.

As mentioned in the Auditor Guidance for Use of Cyanide Transportation Verification Protocol (October

2009), General Guidance notes, consigners are not able to conduct inspections and checks on shipping

vessels due to Port safety and security issues.

Maersk´s vessels are registered by the Lloyd´s Register Group, which provides classification and certification

of ships, and inspects and approves important components and accessories. Maersk also has current

certificates for its vessels under the International Ship and Port Security (ISPS) Code developed by the IMO.


MSC, headquartered in Geneva, Switzerland, is engaged in worldwide container transport. MSC operates

approximately 480 container vessels with the capacity to handle the equivalent capacity of 2.6 millon 20 foot

containers. MSC has set up dangerous goods cargo management centers that manage the stowage of

hazardous cargo worldwide through their MSC Link computer system headquartered in Antwerp. This

hazardous cargo system is initiated when hazardous cargo is booked in the container booking MSC Link

computer system.

MSC{s vessels are registered by the Lloyd{s Register Group, which provides classification and certification of

ship, and inspects and approves important components and accessories.


MSC, headquartered in Geneva, Switzerland, is engaged in worldwide container transport. MSC operates

approximately 480 container vessels with the capacity to handle the equivalent capacity of 2.6 millon 20 foot



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containers. MSC has set up dangerous goods cargo management centers that manage the stowage of

hazardous cargo worldwide through their MSC Link computer system headquartered in Antwerp. This

hazardous cargo system is initiated when hazardous cargo is booked in the container booking MSC Link

computer system.

4. Port of Tianjin, China

The Port of Tianjin is the largest man made sea port in mainland China and forms and important trade trade

port between northern China and north-east, central and western Asia. Located 160 km from Beijin and 60

km from the city center of Tianjin, it covers a land area of 131 square km, and land and sea area of 336

square km.

The Port of Tianjin in composed of five primary port areas:

Tianjin North Port – operation of containers and general cargoes

Tianjin South Port – dry bulk and liquid bulk cargoes

Tianjin East Port – container terminal operation and modern services of international shipping,

logistics, trade and off-shore finance.

South Zone of Harbor Economic Area – heavy equipment manufacturing, new energy food and light

industry.

East Zone of nangang port – new port area for bulk cargo of coal and ore.

There are 159 different vessel berths in Taijin Port, In 2013, the cargo throughput of Taijin Port exceeded

500 million tons; container throughput exceeded 13 million twenty equivalent units (TEU). By 2017, the cargo

throughput of Tianjin Port will exceed 600 million tons and container volume will surpass 20 million TEUs.

China is a Category A member of the International Maritime Organization (IMO) Council and a signatory to

the Tokyo MoU, and as such strictly performs its Ports State obligations, supervises foreign ships in Chinese

waters, and promotes compliance with international conventions among Flag States through Port States

Control (PSC).

Tiajin Port (Group) Co. Ltd. (TPG) is the main body of Tianjin Port and owns the Port, and must be informed

of all ship movements and major operations. The production schedule (ship movement plan) is arranged by

the TPG Dispatch Control Center in coordination whit the wharf operators, the MSA, and the pilot center. The

Dispatch Center organizes ship movements, tracks pilotage operations, and supervises terminal operations

via real-time CCTV monitoring.

On August 12 2015, a fire and subsequent explosions occurred at a dangerous goods warehouse located in

the Tianjin Binhai New Area of the Tianjin, killing 165 people and resulting in significant infrastructure and

property damage. The Accident Investigation Report released in February 2016 by the Chinese regulations

relating to the storage and management of dangerous goods. A number of the investigation

recommendations included changes to port security, stricter regulation and monitoring of hazardous

chemicals, and to strengthen emergency response capabilities.

Following the incidents, it was reported thet the Port of Tianjin stopped accepting hazardous cargo, including

import and export cargo. Hazardous cargo arriving al the Port of Tianjin was allowed to be re-stowed. It is

unclear whether the Port of Tiajin has since has since begun accepting the import/export of hazardous cargo;

this due diligence assumes the Port of Tianjin is currently accepting hazardous materials including sodium

cyanide.

5. Port of Qingdoa, China



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The Port of Quingdoa is located between the Bohai Rim port region and the Yangtze Rize Delta port region

and is an important hub for international trade and transportation in the West Pacific, maintaining shipping

routes to over 700 ports in over 180 countries and regions around the world.

The Port of Quingdao Area – four terminals with 18 berths operated by the Dagang Branch, primarily

for handling steel, aluminum oxide, bauxite, fertizer, metal ore, coal and other general cargo.

Quianwan Port Area – ten terminals with 36 berths operated through the Qiangang Branch (joint

venture between QQCT and West United), primarily for containers, metal ore, coal, pulp and other

general cargo.

Huangdao Oil Port Area – five terminals with 11 berths operated through the joint venture Qingdao

Shihua, primarily for liquid bulk cargo.

Qingdao New Port Area (Dongjakou Port Area) – one terminal with two berths operated by the joint

venture Huaneng Qingdao, primarily for handling metal ore, coal and other general cargo.

Qingdao Port International Co., Ltd. Is the primary operator of the Port of Qindao providing port-related

services ranging from basic port services, such as stevedoring and storage services, to ancillary and of the

Port of Qingdao exceeded 14 million twenty equivalent units (TEU).

The Port of Qingdao also serves as a container transshipment hub for ports in the Bohai Rim region, along

the Yangtze river, as well as in Japan and South Korea.

In addition to stevedoring services, the Port of Qingdao provides assorted port services for containers,

incluiding short-term storage, vaning and de-vanning, and container repair services. Specialized storage

services for containers with non-standard goods, such as frozen goods and hazardous subsatances are also

offered at the Port of Qingdao.

On August 12 2015, a fire and subsequent explosions occurred at a dangerous goods warehouse located in

the Tianjin Binhai New Area of the Port of Tianjin, china. Following these incidents, the port of Quindao was

temporarily suspended form storaging hazardous cargo of Class 2.1, Calss 4 (excluding sulfur UN

1350/CLS4.1) & Class 5 (UN2465 and UN2468) in their hazardous warehouse (including transshipment and

importing). Following a review of dangerous goods security and handling by Quingdao Port (Group) Co. and

by individual freight companies, the port of Qingdao was again authorized to receive and export dangerous

goods including Sodium Cyanide.

China is a Category A member of the International Maritime Organization (IMO) Council and a signatory to

the Tokyo MoU, and as such strictly performs its Ports State obligations, supervises foreign ships in Chinese

waters, and promotes compliance with international conventions among Flag States through Port States

Control (PSC).

5. Port of Callao – Peru

The port of Callao, officially the Callao Port Terminal, is a seaport on the central coast of Peru, in the south-

eastern Pacific, also belonging to the city of Callao in Callao.

It is the country's main port traffic and storage capacity. It is also one of the most important in Latin America

ranking in 7th place and 1st place in the South Pacific region in 2015.

Has a depth of 16 meters, which can receive ships carrying up to 15,000 TEU, has three concessions which

responds to the APN (National Port Authority) in charge of Dubai Ports World (South Dock) and APM

Terminals ( North) dock, and Transportadora Callao SA

Port infrastructure has improved in recent years due to various investments that have been made

concessions product. El Callao There are five springs (1,2,3,4 and North), which are direct berth, breakwater

type.



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There are eleven stores in various areas. There are four areas for containers and five container yards.

Additionally, a closed specialty store grains. There are two ZPMC cranes post-panamax six plus two quay

cranes. There are about 4 mobilizers, 22 terminal trucks, and 10 elevators, of different capacity (2.3, 3.2, 5.5

and 30 tonnes).



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SUMMARY AUDIT REPORT

FOR CYANIDE TRANSPORTATION OPERATIONS

Instructions

1. The basis for the finding and/or statement of deficiencies for each Transport Practice should be

summarized in this Summary Audit Report. This should be done in a few sentences or a paragraph.

2. The name of the cyanide transportation operation, lead auditor signature and date of the audit must be

inserted on the bottom of each page of this Summary Audit Report.

3. An operation undergoing a Code Verification Audit that is in substantial compliance must submit a

Corrective Action Plan with the Summary Audit Report.

4. The Summary Audit Report and Corrective Action Plan, if appropriate, for a cyanide transportation

operation undergoing a Code Verification Audit with all required signatures must be submitted in hard

copy to:

International Cyanide Management Institute (ICMI)

1400 I Street, NW, Suite 550

Washington, DC 20005, USA

5. The submittal must be accompanied by 1) a letter from the owner or authorized representative which

grants the ICMI permission to post the Summary Audit Report and Corrective Action Plan, if necessary,

on the Code Website, and 2) a completed Auditor Credentials Form. The lead auditor’s signature on

the Auditor Credentials Form must be certified by notarization or equivalent.

6. Action will not be taken on certification based on the Summary Audit Report until the application form for

a Code signatory and the required fees are received by ICMI from the applicable cyanide transportation

company.

7. The description of the cyanide transport company should include sufficient information to describe the

scope and complexity of its operation.



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Auditor’s Finding

This Operation is:

X in full compliance

in substantial compliance

not in compliance

with the International Cyanide Management Code.

Audit Company: ISOSURE SAC | CIANURO INCORPORATED EIRL

Audit Team Leader: Luis Torres Argandoña


Date(s) of Audit: 14 March 2016 to 04 May 2016

I attest that I meet the criteria for knowledge, experience and conflict of interest for Code Verification Audit

Team Leader, established by the International Cyanide Management Institute and that all members of the

audit team meet the applicable criteria established by the International Cyanide Management Institute for

Code Verification Auditors.

I attest that this Summary Audit Report accurately describes the findings of the verification audit.

I further attest that the verification audit was conduct in a professional manner in accordance with the

International Cyanide Management Code Verification Protocol for Cyanide Transportation Operations and

using standard and accepted practices for health, safety and environmental audits.

Name and Signatures of Other Auditors

Name Position Signature Date

Luis Torres Argandoña

Lead Auditor, Production and Transportation

Technical 04 May 2016

Carlo Vargas Transportation Technical 04 May 2016


1 TRANSPORT

Transport cyanide in a manner that minimizes the potential for accidents and releases.

1.1 TRANSPORT PRACTICE 1.1

The International

Cyanide

Management Code



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SELECT CYANIDE TRANSPORT ROUTES TO MINIMIZE THE POTENTIAL FOR ACCIDENTS AND RELEASES.

X in full compliance with

The operation is in substantial compliance with Transport Practice 1.1

not in compliance with

Summarize the basis for this Finding/Deficiencies Identified:

The operation is in FULL COMPLIANCE with Standard of Practice 1.1 requiring an operation Select cyanide

transport routes to minimize the potential for accidents and releases.

The MERCANTIL operation for the transport and storage of sodium cyanide was subject to an audit. The

Auditor was verifies and all questions related to the transport protocol ICMI were answered.

MERCANTIL has the procedure for the Transport of Sodium Cyanide, whose goal is to transport sodium

cyanide, without causing damage or injury to persons and / or the environment and the preservation of

substances transported from port of Callao to CONTRANS (Distribution Warehouse MERCANTIL

contracted) to the point set by the client or ALMACENERA EL PACIFICO (Company certified by the Code).

All activities associated with Transport Practice 1.1 are performer by TRANSMERIDIAM (Transportation

Company)

TRANSMERIDIAN implemented the route evaluation process identified as “TRANSP-TRA-002 Development

of Roadmaps”, Cyanide Transport which describes the items to be assessed during the route analysis in

accordance with the ones pointed in the International Cyanide Management Code.

“Emergency Response Plan”, has been implemented for the route related to the cyanide transportation.

The route is evaluated:

Port of Callao – Warehouse Mercantin | Lurin

Mina Brocal | Yauli

The evidenced records are as follows

Roadmap

Risks of Cyanide Transportation

The evaluated routes have been approved by the Ministry of Transport of Peru. The service has been

approved by the National Superintendency of Taxation of Peru.

MERCANTIL designated by the carrier for the transportation service conducts an annual review of the criteria

used for evaluation of the route to: traffic density, cities, bridges, canals, road conditions, route design

(curves, berms, number of lanes), altitude, crossroads, detours, weather conditions and the socio-political

conditions complying with the provisions of the Code.

TRANSMERIDIAN implemented the “TRANSP-TRA-002 Development of Roadmaps”, in the route evaluation

report the major risks were identified as the urban areas, population density, road infrastructure, proximity to

water bodies, presence of fog, likelihood of free fall.

In the evaluation report route was identify as a major risk: Urban areas, high traffic, speeding vehicles,

winding road (characteristics of the Peruvian geography), and transport of other dangerous goods.



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MERCANTIL states that in conjunction with the Transport Company must conduct the evaluation of the route

prior to the first transport to a customer base or annual basis by the Chief Safety Officer Safety or the

Transportation Company and Chief operations. MERCANTIL states that in conjunction with the transport

company must conduce the evaluation of the route prior to the first transport to a customer base or annual

basis by the Safety Officer or Safety Manager of the carrier and a Chief operations MERCANTIL cyanide.

The evaluation of the route will be regularly update by the carrier MERCANTIL and find new de Cyanide of

the MERCANTIL.

The evaluation route is performed annually by the transport company hired MERCANTIL. During the

evaluation of route MERCANTIL staff participates with the staff of the transport company.

The Safety Officer or Safety Manager of the carrier and Chief Operating MERCANTIL cyanide is responsible

for the development of the "Road Map" must consider the following points during the evaluation:

Data Path: Start / End

Stretches of road: description of the section in km.

Total kilometers traveled stretch

Maximum speed limit on the stretch

Altitude meters above sea level.

Type and road conditions / speed allowed

Population

NOTE if check blind spots in the path analysis, they will be assess as a danger the safety and the driver will

provide the necessary communications equipment to maintain communications throughout the route.

Technical stops, Fire Stations and Hospitals or Medical Centers in the area, as well as phone and contacts.

According to “TRANSP-TRA-002 Development of Roadmaps”, routes are verified entirely once a year or to

the first transport to a client by TRANSMERIDIAN´s Control and Analysis team. In addition, for all cyanide

transportation operations, the driver must present a travel log, in which the driver has to note if there were

any changes on the route. If any changes are identified, these are reviewed and assessed; and if applicable,

the route risk assessment is updated. Temporary changes, such as route diversions, are verbally informed to

the driver prior to the departure of the convoy.

TRANSMERIDIAN identified the fire stations, Police stations, technical support and hospitals and medical

centers in the area, as well as phones and contacts.

As previously noted, the risk assessment of each routes describes the risks identified along them and the

specific measures to be taken to address the risks.

The existence of letters sent to the fire companies and medical centers to communicate their roles in case of

any emergency and open communication channels between MERCANTIL and emergency support centers

were check. Each of the support centers that are consider in the Emergency Plan MERCANTIL sealed these.

Among the letters were consider emergency support centers (fire companies and medical centers) near

MERCANTIL and routes used by carriers hired by MERCANTIL.

TRANSMERIDIAN includes comments from interested parties (communities, other stakeholders, government

agencies) in compliance with the procedure " TRANSP-TRA-002 Development of Roadmaps". These

comments if applicable according to its usefulness in the selection of routes and risk management are

reflected in the registry “Roadmap”.

The centers are included in the Emergency Response Plan of TRANSMERIDIAN and consultation centers

were evident during the audit.



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For the transport of sodium cyanide MERCANTIL asks its carriers have a control room also carriers with

GPS system continually provide the positioning of each of the vehicles at all times. As well as continuous

speed supervision at each point of the route from the starting point to the end then this information delivered

to the Safety Officer MERCANTIL.

MERCANTIL also establishes specifications using trucks escort during the transit of sodium cyanide being

due to use ONE (01) escort van for every three (03) or fewer units of traffic load.

Only you can upload ONE (01) Container for each platform and can only drag a wagon chassis. The convoy

may include one or more escort vehicles at your request. Convoy displacement is dependent on weather

conditions; Convoy Leader evaluate the safety of the route in each case, may stop the convoy if satisfied that

the conditions do not allow safe travel.

After each trip, the convoy leader must serve the "Trip Report" where findings that compromise safety during

transport they are included within the assessment route for modification evidences.

TRANSMERIDIAN has a control room at the base of CALLAO, Peru, where the GPS system provides

continuous positioning of each of the vehicles at all times, as well as continuous monitoring of the velocity at

each point of the route from the starting point to the end point.

TRANSMERIDIAN also established through a “P-TRA-001 Transportation Sodium Cyanide”, the

specifications of use of escort trucks during the sodium cyanide transportation, which should be ONE (01)

escort truck for every THREE (03) or less units of cargo transportation. A safety specialist and one driver

travel in the escort vehicle. This requirement applies to all customers of TRANSMERIDIAN.

There can only be charged ONE (01) CONTAINER per platform and each wagon can only drag one chassis.

The convoy may include one or more escort vehicles at the client’s request. The travel of the convoy will

depend on weather conditions; the Convoy Leader shall evaluate the safety of the route in each case, being

able to stop the convoy if he considers the conditions do not allow safe transit.

MERCANTIL and TRANSMERIDIAN information given (MSDS, emergency record and record of product

information) to support emergency centers (health centers and fire companies) along the above routes,

evidenced by a letter signed and received with such information. This activity is carry out for external support

centers could be prepare for emergencies. In addition, external support centers comments are ask to

manage risk as a way to query and get feedback.

When MERCANTIL carrying sodium cyanide, the control room of Transport, continuously provide the

positioning of each of the vehicles at all times, as well as continuous monitoring of the velocity at each point

of the route. This control done through geofencing these indicate the maximum and minimum speed of the

train each way along the route based on information provided by the roadmap.

Mercantil subcontract the cyanide transport operations (TRANSMERIDIAM).


ENSURE THAT PERSONNEL OPERATING CYANIDE HANDLING AND TRANSPORT EQUIPMENT CAN PERFORM THEIR JOBS

WITH MINIMUM RISK TO COMMUNITIES AND THE ENVIRONMENT.






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The operation is in FULL COMPLIANCE with Standard of Practice 1.2 requiring an operation Ensure that

personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to

communities and the environment.

MERCANTIL procedure establishes minimum requirements for drivers: health, legal, defensive driving

training, emergency response training with sodium cyanide (spills and poisoning prevention).

MERCANTIL establishes criteria for the evaluation of the route to: traffic density, cities, bridges, canals, road

conditions, route design (curves, berms, number of lanes), altitude, intersections, detours, weather

conditions and the socio-political conditions. MERCANTIL states that transport companies that hires must

use the criteria thereof which are audited by MERCANTIL annually as a result of the audit verifies that

carriers comply with the standards set MERCANTIL by the same audit MERCANTIL evidence carriers use

trained, qualified and licensed operators to operate their vehicles. In the same way, it is evident that all staff

and transport equipment are in a position such that the possibility of cyanide releases and exposures are

minimize.

The TRANSMERIDIAN procedure (P-TRA-001 Transportation Sodium Cyanide) establishes minimum

requirements for drivers “Job profile”: health, defensive driving training, and response training on sodium

cyanide emergencies (spills and poisoning prevention).

The auditor reviews the documentation of the 05 drivers and 01 supervisor

- Ordoñez Damian, Juan Carlos - Driver

- Echavaudis Cardenas, Cirilo - Driver

- Flores nores, Hector - Driver

- Ventura Rosales, Hector Luis - Driver

- Castillo Cruz, Giovanni - Driver

- Casas Caycho, Jose Antonio – Supervisor

MERCANTIL, warehouse CONTRANS in Callao, each year all staff (the warehouse and transport) has to go

through different types of training, including new staff from scratch. There is a matrix for training. They are

divide into sections for safety and routine work. Special training is carry out by the fire department and

external entities specialists.

MERCANTIL has a special department within Human Resources to develop, implement and verify these

workouts.

MERCANTIL has staff trained in safe handling and storage of sodium cyanide, the Annual Training Program

2016, in which training for warehouse staff and people of Transportation Companies evidenced, was evident.

In addition, he proceeded to interview two (02) equipment operators in operations management and storage

of sodium cyanide. The MERCANTIL does subcontract handling Storage Operation, and subcontract the

Transport Operation Practice 1.1 are performed by ICMI.

TRANSMERIDIAN selects the most specialized drivers to transport sodium cyanide.

According to P-TRA-001 Transportation Sodium Cyanide, drivers drive up to FIVE (05) continuosly, with

breaks of TWO (2) hours. Sleep at least EIGHT (08) hours before each trip, and one must not drive for more

than TEN (10) hours per day.

In their Cyanide Emergency Response Plan, TRANSMERIDIAN includes a training program that must be

complemented by all drivers, consisting of the following:



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Introduction to the Company

Basic Ricks Prevention and Use of Personal Protection Equipment (PPE)

Hazardous Materials Handling and Transportation Nivel 1 and 2

Emergency Response

Defensive Driving

In addition, the following training courses are specific to drivers transporting cyanide shipments:

Cyanide First Emergency Response

General Information of Cyanide Product

According to Plan cyanide related training is refreshed once a year. During the audit, files of three drivers

were reviewed, and all relevant training certificates were available.


ENSURE THAT TRANSPORT EQUIPMENT IS SUITABLE FOR THE CYANIDE SHIPMENT.





The operation is in FULL COMPLIANCE with Standard of Practice 1.3 requiring an operation Ensure that

transport equipment is suitable for the cyanide shipment.

MERCANTIL states that Transport Companies hired must have a maintenance procedure and planning of it,

this requirement is audit by the Safety Officer MERCANTIL annually according to the program without

warning. MERCANTIL also states that hire companies must meet the requirements of ICMI and the Ministry

of Transport and Communications (MTC) of Peru.

TRANSMERIDIAN provides that the charge should not exceed the carrying capacity, and this control is

performed by using the format "Verification Pre-Use Units".

The maintenance of the units is done by the "DIVEMOTORS" supplier, the parts are original and technicians

are specialized for the type of vehicle.

MERCANTIL states that vehicles will be hired lowboy trailers with a maximum load capacity of 22 tons, which

are certify to transport sodium cyanide by the Peruvian government.

In addition, before each trip MERCANTIL staff verifies that vehicles are fit to travel and meet the

requirements described above.

For service storage of sodium cyanide (cylinders and boxes), MERCANTIL has evidence of procedures for

these operations. It was evident he was about a maintenance plan that contains the equipment for handling

cyanide, which states: manufacturer, make, model and serial numbers and kinds of maintenance that must

be maintain in accordance with the guidelines of manufacturer.

Evidences of dates and hours of service for maintenance - the equipment was verify.



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Prior to their loading and use trucks are inspected by staff MERCANTIL to demonstrate any deviation that

jeopardize the operation, based inspection in the format "Checklist Previous -Trip" if find any deviation is

made the communication with the company carries for prior to the start of the operation solution.

After the load is, fixed MERCANTIL makes a record of the weights and measures to record the weight of the

load and verify that this does not exceed the maximum set of 20 TM as established in Peruvian Law by type

of vehicle configuration.

In addition, there are in all the routes used, controls weight and size of the Ministry of Transport and

Communications (MTC) of Peru.

Before giving the output of unit personnel MERCANTIL check that the carrier has the following duly

completed documents:

Referral Guide Submitter

Carrier Referral Guide

Tract Property Cards and Semi-Trailer

Proof of registration of the vehicle in the National Register of Road Transport Hazardous Materials

and Waste issued by the Ministry of Transport and Communications MTC (tractor and semi-trailer).

Circulation Card MTC

Driver's License driver

Course Freight ERM

National Identity

Data Sheet Material Safety Data Sheet (MSDS) Sodium Cyanide

Primer Product Safety Contingency Plan for the Transport of Sodium Cyanide

Certificate of Technical Inspection for transporting hazardous materials

Liability Policy

Cash or Risk

In addition, MERCANTIL staff inspects the forklift, considering the following points: Suitable for a transporter

tonnage, lower antiquity to 5 years. Exterior and interior of the unit in good condition (no damage), forklift

mast in good condition (no cracks or breaks), cleaning the unit as mirrors in good condition and complete,

safety belts and operating clean, no signs of leaking oil, coolant or fuel, parking brake operative, operative

wheels, alarm, back in good state.

According to through the the “P-TRA-001 Transportation Sodium Cyanide”, TRANSMERIDIAN safety chief

together with a driver have to check the trucks and trailers completing a checklist per vehicle prior to the

departure of the convoy.

During the audit, three (03) bundles of travel records who met the provisions of the “Control of Hazardous

Merchandise”, is evidenced for MERCANTIL and TRANSMERIDIAN.

There are documented procedures that set the conditions in place to prevent overloading of the transport

vehicle used for cyanide management; these include issues of safety and environment, as quoted below:

Inspection of packaging

Sobriety

Control of HCN Levels

Check List loading and unloading

Check List container reception

Procedure for Cargo and Storage Discharge

Risk Assessment Matrices

Contingency Plan - Cyanide Management



17

The operation of loading and unloading of sodium cyanide is carry out in the switchyard outside the store, in

front of the storage area Sodium Cyanide. During loading and unloading, has surveillance by a Warehouse

Supervisor CONTRANS and Safety Inspector MERCANTIL.

According to the P-TRA-001 Transportation Sodium Cyanide, TRANSMERIDIAN has procedures in place to

prevent overloading of the transport vehicles, one CONTAINER of cyanide can be loaded on the vehicle. As

seen in the "DS 058-2003-MTC, Standard Weights and Measures Vehicular" (Law of Peru).


DEVELOP AND IMPLEMENT A SAFETY PROGRAM FOR TRANSPORT OF CYANIDE.





MERCANTIL and TRANSMERIDIAN established a transportation method avoiding disturbances during

motion describing the administrative, operational and safety measures for the smooth operation of the

transport of sodium cyanide.

For the transport of sodium cyanide, TRANSMERIDIAN requests that the carrier count with a control room,

with the GPS system continuously provide the positioning of each of the vehicles at all times.

Before the trip, MERCANTIL and TRANSMERIDIAN verifies that the three visible sides of the vehicles are

equipped with UN Number, NFPA diamond and diamond DOT. Peruvian law fulfilled Supreme Decree 021-

2008-MTC Regulation for the transport of hazardous materials / waste.

MERCANTIL check out by prior agreement of inspection units by MERCANTIL Staff to ensure that vehicles

and escort vehicles are in good condition.

TRANSMERIDIAN indicates the need for conformity of the client, to ensure that the escort vehicles and

transport vehicles are in optimal conditions.

TRANSMERIDIAN conducts vehicle inspections prior to each departure/shipment

During the audit process, records of inspections prior to each departure shipment are evidence.

MERCANTIL audited annually and unexpectedly the maintenance plan of the transport companies and the

maintenance records of the units are revised, MERCANTIL has a prevent maintenance plan of the units and

was review maintenance records and practice was confirmed during the observation and was evident in the

interview with MERCANTIL Safety Supervisor, and Drivers.

TRANSMERIDIAN has a maintenance plan. The maintenance records were reviewed and the practice was

confirmed during the observation of the vehicle and interview with the maintenance supervisor and drivers.

MERCANTIL states that Drivers Transportation Companies should rest at least 8 hours before a trip and do

not drive more than 12 hours a day and daylight driving only during the day. It is noteworthy that the

Peruvian rules provide the same hours for the transport of hazardous materials "DS 009-2004-MTC

Regulation of Transport Management Act“.



18

MERCANTIL places the burden of cyanide must travel in containers of 20 feet or 40 feet, developing

mechanisms to prevent movement.

MERCANTIL set your procedure; MERCANTIL supervisor in the warehouse must verify that the load must

be properly secured in the container, during the visit by staff indicated that if necessary elements are used to

secure the load so that the load does not move inside the container.

According to the P-TRA-001 Transportation Sodium Cyanide, TRANSMERIDIAN has anchoring mechanisms

for the container and lashing system for cyanide in the container.

MERCANTIL states that the trip will take place in the way of convoy; the Convoy Leader is responsible for

the assessment of weather conditions and is empowered to suspend the transport convoy.

At the end of the trip, the leader of the operation and drivers must submit a report detailing the same route

incidents, advance information, and find relevant and sensitive areas to ensure the safety and Safety

information on future trips.

MERCANTIL has a Policy of ZERO consumption of alcohol and drugs or any other substance that may

impair or reduce the function of the transport driver. Prior to the commencement of activities necessary to

perform a test alcohol test and periodically discard evidence of drug use, the violation of this policy has

resulted in the separation of the worker from the organization.

TRANSMERIDIAN has “Alcohol and Drug Policy” It is prohibited the consumption of alcohol, drugs or any

other substance that may impair or reduce the function of the driver or a member of the convoy in which prior

to the start of each trip everyone must go through an alcotest and periodical drug tests; the violation of this

policy results in the separation of the worker from the operation.

Plans and procedures for compliance with the Code are review annually and annual follow-up audits will be

develop to verify compliance with standards of MERCANTIL and TRANSMERIDIAN.

MERCANTIL establishes guidelines to ensure that their subcontractors comply with items 1, 2 and 3 of this

must be respected according to the Transport Practice 1.4.

1.5 TRANSPORT PRACTICE 1.5:

FOLLOW INTERNATIONAL STANDARDS FOR TRANSPORTATION OF CYANIDE BY SEA AND AIR.





MERCANTIL ships its sodium cyanide on main line ocean carriers that have demonstrated safety programs

and safe performance. The ocean carriers sign standard contractual agreements that require that the carrier

adhere to applicable regulations and have “organized safety programs.”

Contracts were reviewed during the audit and this standard clause appears in the ocean carrier contract.

Each carrier was asked for information regarding fulfillment of ICMI Cyanide Code requirements using a

customized ICMI transportation protocol. Responses and information provided by all ocean carriers was

deemed to be appropriate by the auditor.



19

The MERCANTIL Ocean Carrier contracts require that all transportation is conducted in accordance with all

regulatory requirements.

The ocean routes are chosen by the ocean carriers. Destination ports are evaluated by the MERCANTIL.

This is done prior to the first shipment of product to a new location. Records were available to show that port

evaluations had been conducted at each of the international ports used in this Supply Chain. MERCANTIL

has also concluded that the Homeland Security infrastructure that is available to assist ports with regard to

security and emergency response is sufficient to conclude that ICMI Cyanide Code requirements are fulfilled.

The auditor concluded that MERCANTIL has effective processes for ensuring that international ports have

demonstrated appropriate safety, security, and road infrastructure prior to being approved for hazardous

material shipments.

As recommended by the ICMI Auditor Guidance for the Use of the Cyanide Transportation Verification

Protocol, specific information regarding this practice is addressed below:

a) The MERCANTIL packaging specifications were reviewed as part of the verification audit and were

found to be conformant to the packaging requirements of the IMDG Code.

b) Packaging for drums and IBCs reviewed as part of the due diligence evaluation were appropriately

marked and were found to be compliant with Chapter 5.2 of the IMDG Code requirements.

c) Packaging for drums and IBCs reviewed as part of the due diligence evaluation were appropriately

labeled and were found to be compliant with Chapter 5.2 of the IMDG Code requirements.

d) Loaded inter-modal containers were evaluated and were found to be marked and

e) placarded in accordance with the IMDG Code.

f) Shipping documents were reviewed for a sample of cyanide shipments from January 2016 through

April 2016 for each ocean carrier used in this supply chain. All information required by the IMDG

Code is required as standard practice on MERCANTIL shipping paperwork.

g) The container packing certificates from 2016 shipments were reviewed during the audit as part of the

overall evaluation of shipping papers. All information was found to be conformant to IMDG Code

requirements.

h) MERCANTIL maintains records which show that the ocean transport is conducted in compliance with

all international and DOT (U.S. Department of Transportation). The ocean carriers confirmed to

MERCANTIL that they have cyanide emergency response information available on board each

vessel.

i) MERCANTIL maintains records which show that the ocean transport is conducted in compliance with

all international and DOT requirements.

MERCANTIL not transported by air transport.


TRACK CYANIDE SHIPMENTS TO PREVENT LOSSES DURING TRANSPORT.





The operation is in FULL COMPLIANCE with Standard of Practice 1.6 requiring an operation Track cyanide

shipment to prevent losses during transport.



20

MERCANTIL states that contract carriers must use a GPS system. They must also have a telephone service,

radio and cellular pathway that ensures full coverage during movement and be fully connected to the control

room where his base and MERCANTIL. In addition to providing, a system that continuously indicates the

position of each vehicle at all times.

TRANSMERIDIAN uses a GPS system. They also have telephone service, radio UHF and cell phones which

ensure full coverage during movement and are completely connected to the control room in their base in

CALLAO, Peru. In addition to providing this system, they continually know the positioning each of the

vehicles all the time and the safety escort vehicle carries a satellite phone. During the audit, the operability

equipment was verified.

MERCANTIL inspects the telephone lines are in operation prior to departure, further checks are done to

verify the operation of mobile equipment, GPS and radio by List Pre-Trip Inspection Authority.

Additional, MERCANTIL periodically test communication equipment to ensure it functions properly.

The phone lines were operating at the time of the audit; and also an inspection was done to verify the

operation of mobile equipment and it was found the payment of the phone, the GPS, satellite phone and the

radio UHF services.

Additional, TRANSMERIDIAN periodically test communication equipment to ensure it functions properly.

"Verification Pre-use units" contains the inspection criteria of communication equipment.

MERCANTIL and TRANSMERIDIAN have identified areas without cell coverage and radio, for it asks

MERCANTIL contract carriers using satellite equipment.

MERCANTIL and TRANSMERIDIAN verifies that the GPS system have transport companies that hire has

location updates in real time also continually sought (periods not to exceed one hour) the location of the

transport units.

Before each trip MERCANTIL check the bill of lading and waybill, transported amounts of cyanide, Data

Sheet Material Safety also this documentation must be available throughout the trip as MERCANTIL

guidelines, this same data is review by Customer (final destination). Note that this information must be show

to the inspectors if MTC is request otherwise the carrier be fine.

MERCANTIL is secure before each trip that the sender reference guide to indicate the product name,

number of the United Nations (UN), and weight of packages transported cargo quantity, and likewise that

product safety considerations indicated.

Upon delivery of the send, reference guide supplied Data Sheet Material Safety to the carrier. The lack of

guidance sender reference and Data Sheet Material Safety during transport is fine by the confiscation of the

cargo by the Peruvian government that makes mandatory controls on all tolls departure City Lima. It is worth

mentioning that the sender reference guide should be preserve and stored by the carrier for not less than

five (05) years’ time.

MERCANTIL establishes guidelines to ensure that their subcontractors comply with the elements 1 to 6 of

this, should be respected according to the Transport Practice 1.6.



21

2 INTERIM STORAGE

Design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent

releases and exposures.


STORE CYANIDE IN A MANNER THAT MINIMIZES THE POTENTIAL FOR ACCIDENTAL RELEASES.





The operation is NOT APPLICABLE whit Standard of Practice 2.1 requiring an operation Store cyanide in a

manner that minimizes the potential for accidental releases.

MERCANTIL within the supply chain hires CONTRANS as a distribution warehouse.



22

3 EMERGENCY RESPONSE:

Protect communities and the environment through the development of emergency response

strategies and capabilities.


PREPARE DETAILED EMERGENCY RESPONSE PLANS FOR POTENTIAL CYANIDE RELEASES.





The operation is in FULL COMPLIANCE with Standard of Practice 3.1 requiring an operation Prepare

detailed emergency response plans for potential cyanide releases.

MERCANTIL has an emergency response plan (EMERGENCY RESPONSE PLAN FOR CYANIDE

TRANSPORTATION). Information on road conditions is defined in the Roadmap document. The Emergency

Plan describes the response actions for anticipated emergency situations. These were verified during the

audit.

The Emergency Response Plans for transportation is suitable for the selected transport route, based on the

hazards and risk assessment after the completion of the ROADMAP.

The Emergency Response Plan is suitable for the selected transport route, taking into account the physical

and chemical form of cyanide clearly based on the Safety Data Sheet of the Product "Sodium Cyanide".

MERCANTIL is a transporter of sodium cyanide supply in solid state (briquettes).

MERCANTIL indicates the use of trucks to transport sodium cyanide taking into account the characteristics

of the equipment and assesses the structural condition of the road where the transportation sodium cyanide

is done.

Information on road conditions is defined in the Roadmap document. The Emergency Response Plan

describes the response actions for anticipated emergency situations. These were verified during the audit.

It also establishes the logical line of action to be taken by the convoy leader and drivers in case irregularities

arise during transportation of sodium cyanide.

MERCANTIL uses trucks; in addition, all shipment is dispatched within low platform trailers purchased with a

maximum load capacity of 30 tons which are certified to transport sodium cyanide by the government of

Peru.

MERCANTIL sets action if incidents occur on the route which is described below.

• Mechanical problems/does not continue

• Rollover with spill

• Rollover with no spill



23

• Fire in the truck

• Crash with injuries/no injuries

• Water spill, cleaning and decontamination

• Spill with rain (falling to the ground, Meltdown, the presence of others, railway, earrings)

Awareness on the part of drivers and supervisors of the actions in each case was evidenced after interview

with the staff.

MERCANTIL has defined three levels of emergency response:

• 1st Response – Product Spill of less than 1 tons.

• 2nd Response – Product Spill of more than 1 tons or Product Spill in contact water.

For 2do Response, MERCANTIL subcontracts External Emergency Responder (IFSEC PERU) and also

contacts the Fire Department, Police, and Emergency Medical Services.

During 2nd Response emergencies, the External Emergency Responder is in charge of the emergency

response actions when they arrive (delimitation of the area, communication, and access and traffic control

are performed by the drivers and the safety specialist while the External Emergency Responder arrives).

However, when the National Fire Department arrives to the scene, they take control of the emergency, as

established by local regulations. This is established in the Emergency Response Plan. Finally, specific roles

of each outside responder are outlined in the Emergency Response Plan.


DESIGNATE APPROPRIATE RESPONSE PERSONNEL AND COMMIT NECESSARY RESOURCES FOR EMERGENCY

RESPONSE.





The operation is in FULL COMPLIANCE with Standard of Practice 3.2 requiring an operation Designate

appropriate response personnel and commit necessary resources for emergency response.

MERCANTIL during the audit has show that Drivers, and Supervisors (TRANSMERIDIAM and CONTRANS)

receive training in emergency response from appropriate personnel on the safe handling of cyanide (spill and

intoxication) and others receive training courses in defensive driving, firefighting, first aid. These trainings are

renewed annually complying with the training plan 2016.

Drivers, Supervisors are responsible to respond in an emergency; they pass through medical tests to verify

their good physical condition to perform these activities and have received the necessary training for efficient

emergency response.

Each truck has the necessary amount of emergency response equipment and the safety escort also has a

Response Kit for spills and poisoning (oxigen), and personal protective equipment which must be verified

before the trip, as well as the verification of courses prior to starting the travels and the periodic emergency

response training.



24

MERCANTIL has the necessary equipment for emergency response in the event of a major spill.

There were verified the records of the emergency response and inspection of equipment. The presence of

such equipment in the convoy was verified. In the Emergency Plan indicates the functions of the staff in case

of an emergency, and also the emergency equipment to be used in both the first and the second response.

The Emergency Plan describes the specific functions of the emergency response and the staff

responsibilities.

In the “Procedure for loading, transportation and unloading of sodium cyanide”, version 0, January 2016, is

specified the verification criteria of the units before each journey.

During the audit, inspection records were evident.

MERCANTIL outsource transport and storage, loading and unloading of cyanide.


DEVELOP PROCEDURES FOR INTERNAL AND EXTERNAL EMERGENCY NOTIFICATION AND REPORTING.





The operation is in FULL COMPLIANCE whit Standard of Practice 3.3 requiring an operation Develop

procedures for internal and external emergency notification and reporting.

It was noticed that the contact information in case of emergency is updated, in case of emergency it will be

set and updated the Emergency Response Plan. The Emergency Response Plan indicates the current

contact list which is reviewed and updated through every review of the Emergency Response Plan.

The Emergency Response Plan includes an internal communication and external schema that specifies the

call flow by the safety personnel, the receptors, the regulatory agencies, external response providers,

medical centers, fire departments, and communities potentially affected by an emergency.


DEVELOP PROCEDURES FOR REMEDIATION OF RELEASES THAT RECOGNIZE THE ADDITIONAL HAZARDS OF CYANIDE

TREATMENT CHEMICALS.







25

The operation is in FULL COMPLIANCE with Standard of Practice 3.4 requiring an operation develop

procedures for remediation of releases that recognize the additional hazards of cyanide treatment chemicals.

It was noticed in the Emergency Response Plan the description of how to recover or neutralize the solids, the

procedure of decontamination of soils or other contaminated medium and how to manage these wastes.

The Emergency Response Plan prohibits the use of chemicals such as sodium hypochlorite, ferrous sulfate

and hydrogen peroxide to treat cyanide that has been released to surface waters.


PERIODICALLY EVALUATE RESPONSE PROCEDURES AND CAPABILITIES AND REVISE THEM AS NEEDED.





The operation is in FULL COMPLIANCE with Standard of Practice 3.5 requiring an operation Periodically

evaluate response procedures and capabilities and revise them as needed.

The period of review and evaluation of this Emergency Response Plan is at least once a year.

The MERCANTIL´s Management is responsible for requesting immediate changes to this Plan, in the event

of serious incidents, by simulation results, results of audits or inspections by process improvement etc.

During the audit, records spill drill evidenced, in January 2016.

The Emergency Response Plan and the Training Plan define the frequency of emergency drills. The

document presents the schedule of emergency simulations.

The simulations are made by the Chief of Safety who has an ANNUAL DRILL PROGRAM indicating the

completion of ONE (01) practical simulation, for the purpose of evaluating the effectiveness of the

Emergency Plan and correct what is indicated on it.

The purpose is to measure the efficiency of the response procedure to ensure that the staff involved in an

emergency act according to the Emergency Response Plan.

The Chief of Safety takes into account the rapid preliminary compilation of the situation, gathering basic facts

as they are known such as time the who, what, where, when, how and why of the situation, contacts the

responsible person and broadcasts the obtained information, and continuously communicates with the

Convoy Leader and will meet the requirements of authorities.



26

INTERNATIONAL CYANIDE MANAGEMENT CODE

MERCANTIL COMMODITY S.A.C.

SUMMARY AUDIT REPORT CODIGO 20552423993

BASE PRODUCTION, CALLAO, LIMA, PERU VERSION 01. 1

FECHA 04/05/2016

In collaboration with:



2

INTERNATIONAL CYANIDE

MANAGEMENT INSTITUTE

Cyanide Production Operations

Summary Audit Report

For The

International Cyanide Management Code and MERCANTIL COMMODITY S.A.C. –

Callao – Lima – Peru


www.cyanidecode.org

May 2016

LIMA, PERU LIMA, PERU

http://www.cyanidecode.org/



3

TABLE OF CONTENTS

INTRODUCTION ................................................................................................................................... 4

1 OPERATIONS ............................................................................................................................... 7

1.1 PRODUCTION PRACTICE 1.1 .................................................................................................... 7 1.2 PRODUCTION PRACTICE 1.2 .................................................................................................... 8 1.3 PRODUCTION PRACTICE 1.3 .................................................................................................... 9

2 WORKER SAFETY ..................................................................................................................... 10

2.1 PRODUCTION PRACTICE 2.1 .................................................................................................. 10 2.2 PRODUCTION PRACTICE 2.2 .................................................................................................. 11

3 MONITORING: ............................................................................................................................ 13

3.1 PRODUCTION PRACTICE 3.1:................................................................................................. 13

4 TRAINING:................................................................................................................................... 14

4.1 PRODUCTION PRACTICE 4.1:................................................................................................. 14 4.2 PRODUCTION PRACTICE 4.2:................................................................................................. 15

5 EMERGENCY RESPONSE: ...................................................................................................... 16

5.1 PRODUCTION PRACTICE 5.1:................................................................................................. 16 5.2 PRODUCTION PRACTICE 5.2:................................................................................................. 16 5.3 PRODUCTION PRACTICE 5.3 .................................................................................................. 17 5.4 PRODUCTION PRACTICE 5.4 .................................................................................................. 18 5.5 PRODUCTION PRACTICE 5.5 .................................................................................................. 18 5.6 PRODUCTION PRACTICE 5.6 .................................................................................................. 19



4

INTRODUCTION

Information on the audited operation

Name of Cyanide Transportation Facility: MERCANTIL COMMODITY S.A.C.

Name of Facility Owner: MERCANTIL COMMODITY S.A.C.

Name of Facility Operator: MERCANTIL COMMODITY S.A.C.

Name of Responsible Manager: Bruno Bellatin Gomez de la Torre

Address: Calle Santorin 243 Santiago de Surco

State/Province/Country: Lima/ Peru

Telephone: +51 618 1616 + Fax: ---


Aspects of the location and description of the operation:

MERCANTIL Commodity S.A.C. (MERCANTIL) has traded sodium cyanide over 20 years. In the Peru, the

solid sodium cyanide briquettes are are imported from different factories around the world. The Global Ocean

Supply Chain is used for shipments from the Port of Tianjin and Quingdao (CHINA) by ocean carrier and

then arriving at the port of Callao they are transported by the company TRANSMERIDIAM to warehouse

CONTRANS, before being transported to stock "MERCANTIL" (ALMACENERA EL PACIFICO S.A.C.,

certified company) or mining customer by certified carriers. The results of the transport, warehouse and

barge audit and due diligence evaluations are contained in a separate report. This certification audit included

the following components.

Global Ocean Supply Chain – All global ocean moves of sodium cyanide that originate in the China and

those that originate at the Port of TIANJIN or QUINGDAO as part of the MERCANTIL Supply Chain are

within the scope of this certification audit. MERCANTIL processes used to manage the ocean transport of its

products were evaluated through interview, a review of process descriptions, company standards, policies,

shipping records, and due diligence records. The results of the due diligence evaluations of THREE (03)

ocean carriers are also contained within this report. The three ocean carriers for which due diligence

investigations were performed are:




The Due Diligence Investigations were also conducted for Golder Associates in use at the time of the audit.

Records were sampled to confirm that MERCANTIL had either evaluated the ports specifically for cyanide

safety handling practices, or that the port had been previously approved and used by MERCANTIL for

hazardous material shipments. The ports listed on the following page are used by MERCANTIL for sodium

cyanide shipments to gold mine customers and were included in this certification audit.

Additionally, the company was evaluated TRANSMERIDIAM transport and Storage Company CONTRANS

located in Peru.



5

SUMMARY AUDIT REPORT

FOR CYANIDE TRANSPORTATION OPERATIONS

Instructions

1. The basis for the finding and/or statement of deficiencies for each Production Practice should be

summarized in this Summary Audit Report. This should be done in a few sentences or a paragraph.

2. The name of the cyanide transportation operation, lead auditor signature and date of the audit must be

inserted on the bottom of each page of this Summary Audit Report.

3. An operation undergoing a Code Verification Audit that is in substantial compliance must submit a

Corrective Action Plan with the Summary Audit Report.

4. The Summary Audit Report and Corrective Action Plan, if appropriate, for a cyanide transportation

operation undergoing a Code Verification Audit with all required signatures must be submitted in hard

copy to:

International Cyanide Management Institute (ICMI)

1400 I Street, NW, Suite 550

Washington, DC 20005, USA

5. The submittal must be accompanied by 1) a letter from the owner or authorized representative which

grants the ICMI permission to post the Summary Audit Report and Corrective Action Plan, if necessary,

on the Code Website, and 2) a completed Auditor Credentials Form. The lead auditor’s signature on

the Auditor Credentials Form must be certified by notarization or equivalent.

6. Action will not be taken on certification based on the Summary Audit Report until the application form for

a Code signatory and the required fees are received by ICMI from the applicable cyanide transportation

company.

7. The description of the cyanide transport company should include sufficient information to describe the

scope and complexity of its operation.



6

Auditor’s Finding

This Operation is:

X in full compliance

in substantial compliance

not in compliance

with the International Cyanide Management Code.

Audit Company: ISOSURE SAC | CIANURO INCORPORATED EIRL

Audit Team Leader: Luis Torres Argandoña


Date(s) of Audit: 14 March 2016 to 04 May 2016

I attest that I meet the criteria for knowledge, experience and conflict of interest for Code Verification Audit

Team Leader, established by the International Cyanide Management Institute and that all members of the

audit team meet the applicable criteria established by the International Cyanide Management Institute for

Code Verification Auditors.

I attest that this Summary Audit Report accurately describes the findings of the verification audit.

I further attest that the verification audit was conduct in a professional manner in accordance with the

International Cyanide Management Code Verification Protocol for Cyanide Transportation Operations and

using standard and accepted practices for health, safety and environmental audits.

Name and Signatures of Other Auditors

Name Position Signature Date

Luis Torres Argandoña

Lead Auditor and Production Technical

04 May 2016

The International

Cyanide

Management Code



7


1 OPERATIONS

Design, construct and operate cyanide production facilities to prevent release of cyanide.

1.1 PRODUCTION PRACTICE 1.1

DESIGN AND CONSTRUCT CYANIDE PRODUCTION FACILITIES CONSISTENT WITH SOUND, ACCEPTED ENGINEERING

PRACTICES AND QUALITY CONTROL/QUALITY ASSURANCE PROCEDURES.


The operation is in substantial compliance with Production Practice 1.1



The operation is in FULL COMPLIANCE whit Standard of Practice 1.1 requiring an operation design and

construct cyanide production facilities consistent with sound, accepted engineering practices and quality

control/quality assurance procedures.

The construction of storage facilities CONTRANS, company hired by MERCANTIL for storage of sodium

cyanide were approved by the District Municipality of Callao, Callao, Peru, and subjected to quality control of

municipal inspectors and customers of MERCANTIL. The designs and drawings submitted were approve

under the structural considerations of seismic, electrical, fire, health, in accordance with the Rules of the

Peruvian Structural Standards risks, and these are sign by a professional engineer qualified referee,

enabling to CONTRANS for the Storage of Cylinders and Boxes with cyanide. These records are available at

CONTRANS and were review during the audit.

The review of building stores CONTRANS is performed by a multidisciplinary group of professionals made

up 01 Structural Engineer 01 Sanitary Engineer, 01, Electrical Engineer 01 and 01 Architect Engineer Safety

and Health at Work, which are qualified referees. This is done every two years and is a requirement of the

Municipality of Callao, Peru to get the "License to Operate" concluding APTA facilities CONTRANS for

storage cylinders and boxes cyanide.

MERCANTIL not handle cyanide state also, MERCANTIL has implement management plan cyanide

“Loading, Unloading and storage of sodium cyanide”.

Cyanide is stacked up four levels. This will be monitors by Supervisor MERCANTIL and should storage

separate from acids, weak alkaline, fuel, water / liquids, food (consume animals or human)

There are quality control and quality assurance documentation. The warehouse built with concrete floor,

brick walls and roof of calamine has a chute end to end to prevent water ingress as secondary containment.

It also has natural ventilation, which consists of windows covered with microfiber, which allows air circulation

and prevents the rain to pass if this was give. The failure or power outage does not affect the operation of

MERCANTIL / CONTRANS nor cause a leak or spill. Warning system for reporting emergency brigade staff

and hazardous materials to meet any spills promptly was evident.



8

The boxes and cylinders of cyanide are stored on a pallet surface, which is on a concrete floor. MERCANTIL

/ CONTRANS not develop activities filling tanks, not involve the use of pipes and tanks for storage of cyanide

or not employ the use of pipes for the storage solution cyanide. The failure or power outage does not affect

the operation of MERCANTIL / CONTRANS nor cause a leak or spill.


DEVELOP AND IMPLEMENT PLANS AND PROCEDURES TO OPERATE CYANIDE PRODUCTION FACILITIES IN A MANNER

THAT PREVENTS ACCIDENTAL RELEASES.





The operation is in FULL COMPLIANCE whit Standard of Practice 1.2 requiring an operation develop and

implement plans and procedures to operate cyanide production facilities in a manner that prevents accidental

releases.

MERCANTIL is aware of the dangers and risks involved in the use of sodium cyanide during storage,

therefore, has developed an emergency plan for cyanide management Emergency Plan - Sodium Cyanide

Management. The Plan allows them to ensure the safety and health of its employees, customers,

contractors, visitors and others; and to fulfill the commitment to prevent or minimize the risk to health in an

appropriate, timely and coordinate emergencies response. MERCANTIL has a procedure in place and

implemented to identify when site operating practices have or will be changed from those on which the initial

design and operating practices were predicated.

Additional, MERCANTIL set to the Emergency Response Plan - Sodium Cyanide, revision of the plan will be

made annually, also if requested by the Peruvian State, Customers, Partners, Suppliers, Emergency Support

Centers.

CONTRANS implemented a program of preventive maintenance of equipment (Forklift and Stackers),

maintenance and repair, which is verify by MERCANTIL. Maintenance records of equipment used for loading

/ unloading and storage of cyanide were check. During the entry or exit from storage, the levels of hydrogen

cyanide (HCN) are control with a calibrated instrument.

MERCANTIL has TWO (02) monitoring equipment.

The Emergency Plan - Sodium Cyanide Management establishes procedures to dispose of cyanide in

contaminated soil. The storage facility MERCANTIL / CONTRANS is build for ventilation naturally, which

allows entry of air entering avoiding rain.

The storage area MERCANTIL / CONTRANS has tin roof and brick walls, additionally has a system of

gutters to catch rainwater and direct it to a sump. It also has a secondary containment system that consists

of a trough which avoids water ingress and this is located opposite the entrance doors of the store.

MERCANTIL makes a Risk Assessment Matrix of loading, unloading and storage. Access to the Warehouse

for MERCANTIL / CONTRANS is restricted, prohibited the public has a perimeter fence 6 feet tall and

security based on two (02) security guards, also has a closed system of security cameras.



9

The cyanide is packaged as required peruvian political jurisdiction.


INSPECT CYANIDE PRODUCTION FACILITIES TO ENSURE THEIR INTEGRITY AND PREVENT ACCIDENTAL RELEASES.





The operation is in FULL COMPLIANCE whit Standard of Practice 1.3 requiring an operation inspect cyanide

production facilities to ensure their integrity and prevent accidental releases.

No tanks containing cyanide solutions in MERCANTIL facilities. No piping, pumps or valves handle cyanide

solutions on site. MERCANTIL / CONTRANS has load-lifting equipment (forklifts and stackers). The lifting

and handling charges are inspecting daily and maintained in accordance with supplier has to do CONTRANS

Maintenance Plan. These records were evidence during the audit.

In the check list be observed, name of inspector, date of inspection, to inspect items and recommendations

on items that are found in the document. During the audit is observed along with inspection records evidence

of lifting the non-compliance is observe.

.



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2 WORKER SAFETY

Protect workers’ health and safety from exposure to cyanide.


DEVELOP AND IMPLEMENT PROCEDURES TO PROTECT PLANT PERSONNEL FROM EXPOSURE TO CYANIDE.






implement procedures to protect plant personnel from exposure to cyanide.

MERCANTIL has developed the method of “Loading, Unloading and Storage of Sodium Cyanide”. This

procedure includes the practices required for receipt, storage and dispatch of cyanide, indicating the needs

of personal protective equipment and training requirements. Relevant staff were interview during the audit

and were well inform of the requirements of the procedures and practices, as do reportedly are in

concordance with what is contained in the procedure.

Since installation is just a storage facility, emergency operations are only included in the Emergency Plan -

Cyanide Management. In addition, maintenance is relate only to forklifts and stackers, held outside the

company premises by the supplier of the equipment.

The site has a Risk Assessment Matrix being responsible Head of Safety to review and update it whenever

significant changes including the cyanide management practices are perform Workers participate in relevant

meetings and review of procedures safety and health issues at work company by the supplier of the

equipment.

Workers participate in relevant meetings of review of issues of safety and health at work which takes at least

once a month or whenever an emergency occurs topics related to health and safety at work are discussed,

review or creating procedures. Furthermore, induction talks was evident to all new personnel hired to work

the stock cyanide in which the safe handling of the product, first aid in poisoning, spill management is

explained.

It is noteworthy that after interviews with staff these declared be consult at any health and safety issue at

work.

MERCANTIL has two (02) controlling detectors cyanide gas concentrations of cyanide (HCN), while

unloading containers of cyanide; detectors are calibrate to alarm at 4.7 ppm. The detectors are calibrate and

a calibration certificate is issue by the manufacturer.

Reportedly, they have not identified areas or activities with concentrations of cyanide gas (HCN). Despite

this, class A Personal Protective Equipment (encapsulated suit) is required in the installation and use of

cyanide when a container is damage and repairs made to it.



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To the "buddy system" is set for establishing activities that cyanide must have minimum two persons and 1

extra person for supervision. Radios and telephones used to communicate between the relevant personnel

related to the operations of cyanide.

Forklift and Stacker operators have radios with them at all times.

Pre-employment medical examinations are required before hiring new staff, periodically while working on

MERCANTIL / CONTRANS, and out MERCANTIL / CONTRANS. Specific requirements are define for

different trades and positions. Relevant documentation was review during the audit in connection with this.

Disposable Suits level C are use as part of the Personal Protective Equipment required tasks in loading and

unloading of cyanide.

There are warning signs posted on the cyanide storage area, advising is that cyanide is present and, if

necessary, the appropriate personal protective equipment should be used. In addition, smoking is prohibited,

dining, and open flames in areas where there is the possibility of contamination by cyanide.


DEVELOP AND IMPLEMENT PLANS AND PROCEDURES FOR RAPID AND EFFECTIVE RESPONSE TO CYANIDE EXPOSURE.






implement plans and procedures for rapid and effective response to cyanide exposure.

MERCANTIL has implemented a couple to care and accident investigation methodology, which aims to

ensure that all accidents and near misses are report and investigated immediately in order to make the

respective corrections. This procedure is the responsibility of the Head of Safety. The procedure is divide into

the accident / incident care, Accident Investigation / Treatment Failure and the accident / incident.

As part of this research, this method indicates that the investigation of the incident / accident must be support

by a report.

MERCANTIL reports no accidents occurred with cyanide or whatever is involved, information validated by

interviews with company personnel operative.

MERCANTIL has Emergency Plan, which deals with spills, fires and poisoning due to exposure to cyanide.

This plan has been included in the Annual Training Plan.

MERCANTIL has portable wash stations eyes low-pressure dry chemical extinguishers 50Kg per house 50

meters. According to eyewash stations, interviewed staff are inspect daily and extinguishers are inspect once

a month.

The facility has water, oxygen tank, antidote and trained personnel to provide first aid (oxygen) to assist an

employee exposed. Employees have the radio for internal communication and installation telephony

features.



12

MERCANTIL has launched an inspection checklist whenever operations are perform with cyanide (loading

and unloading); including minimum amounts of first aid and emergency response teams. Checklists from

January 2016 to April 2016 were review; availability of equipment was confirm during the audit.

The MSDS is in Spanish language and was available off the cyanide storage area. No tanks, pipes or

containers. Allowed only by authorized personnel enter the area. Disposable Tyvek Suit (Level C) is required

to enter the area.

The facility does not have a doctor on site but has a health center 10 minutes away by car you are familiar

with the symptoms of cyanide poisoning and first aid procedures. As oxygen tank mentioned above and

antidote kit are also available on the site.

The Emergency Plan includes a method for transporting workers exposed to the nearest medical facility. This

procedure indicates in which case the exposed worker must be evacuate, and the name and address of the

medical center; how the worker will be expose and the exposed worker is transported at all times.

Written communications with external response were available for review, including the health center. The

communication indicates that the health center will provide medical care for exposed personnel.

MERCANTIL conducted one emergency drill regarding cyanide spill from ruptured box and cylinders.

MERCANTIL has an accident investigation methodology. As part of this research, the process of the

investigation indicates that the incident must be support by a report.



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3 MONITORING:

Ensure that process controls are protective of the environment.

3.1 PRODUCTION PRACTICE 3.1:

CONDUCT ENVIRONMENTAL MONITORING TO CONFIRM THAT PLANNED OR UNPLANNED RELEASES OF CYANIDE DO NOT

RESULT IN ADVERSE IMPACTS.





The operation is in FULL COMPLIANCE whit Standard of Practice 3.1 requiring an operation conduct

environmental monitoring to confirm that planned or unplanned releases of cyanide do not result in adverse

impacts.

MERCANTIL makes the finished product storage CONTRANS, cyanide is not remove from its package;

operations do not generate air emissions or wastewater containing cyanide in normal conditions. The waste

generated by an emergency would be handle as hazardous waste. This section does not apply to facilities.

MERCANTIL makes no discharges to surface waters, stored MERCANTIL presentation end briquettes

packed in boxes and cylinders product. The waste generated by an emergency would be handle as

hazardous waste.

MERCANTIL not perform any type of discharge, terminated MERCANTIL stores briquettes packed in

presentation boxes and cylinders product. The waste generated by an emergency would be handle as

hazardous waste.

MERCANTIL not perform any type of indirect discharge to surface water, stored MERCANTIL finished

briquettes packed in presentation boxes and cylinders product.



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4 TRAINING:

Train workers and emergency response personnel to manage cyanide in a safe and environmentally

protective manner


TRAIN EMPLOYEES TO OPERATE THE PLANT IN A MANNER THAT MINIMIZES THE POTENTIAL FOR CYANIDE EXPOSURES

AND RELEASES.





The operation is in FULL COMPLIANCE whit Standard of Practice 4.1 requiring an operation train

employees to operate the plant in a manner that minimizes the potential for cyanide exposures and releases.

MERCANTIL has an annual training program in which the hazard identification and training is given on risk

analysis (IPER for its acronym in Spanish) to all operators of cyanide. This training is delivering by the Head

of Safety Operations MERCANTIL once a year and lasts one hour. Training records were review during the

audit. The Head of Safety MERCANTIL and Safety Officer CONTRANS maintain all training records

recorded and archived.

The training given to the level of risk the following are described:

First aid

Fire Fighting

Safe Handling of Cyanide (Spill and Intoxication)

Use of PPE

All training sessions included in the annual training program has been designed as a result of hazard

identification and risk assessment to address the risks associated with the activities of each job in the

warehouse.

MERCANTIL provides training programs for workers in annual form, the training program of 2016 on the

entire course "Personal Protective Equipment" included was evident.

MERCANTIL names a person or entity responsible for each training session, all of which are MERCANTIL

qualified staff and external companies. MERCANTIL has a procedure for evaluating potential suppliers in

terms of their suitability to work with MERCANTIL.

According to “Loading, Unloading and Storage of Sodium Cyanide Sodium" all personnel operating cyanide

must have prior training. When interviewed stated that an employee had been trained before the start of its

activities in the company.

MERCANTIL conducts annual drills to test the effectiveness of the training. Also, at the end of training

assessment one hand with a minimum passing grade is 13, if it is done it is necessary to follow the course.

.



15


TRAIN EMPLOYEES TO RESPOND TO CYANIDE EXPOSURES AND RELEASES.





The operation is in FULL COMPLIANCE whit Standard of Practice 4.2 requiring an operation train

employees to respond to cyanide exposures and releases.

MERCANTIL has the Emergency Plan - Sodium Cyanide Management, in which all employees are training in

the different scenarios that could result in a release cyanide as emergently. This is impart by the Chief Safety

MERCANTIL training once a year.

Training Program of MERCANTIL Indicates that must perform TWO (02) exhaust drills of cyanide per year.

Simulations performed are evaluate in terms of effectiveness, to determine the level of knowledge, skills, and

identifying weaknesses of staff and the organization. This assessment was evident in the reports of the drills

conducted in 2016.

Training records were review to confirm the execution of the training program described above. These

records include the names and signatures of the worker as worker and trainer, date of training and the topics

covered. Three Employees were interview and responded correctly to all questions regarding cyanide

management in your work area.



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5 EMERGENCY RESPONSE:

Protect communities and the environment through the development of emergency response

strategies and capabilities.


PREPARE DETAILED EMERGENCY RESPONSE PLANS FOR POTENTIAL CYANIDE RELEASES.





The operation is in FULL COMPLIANCE whit Standard of Practice 5.1 requiring an operation prepare

detailed emergency response plans for potential cyanide releases.

MERCANTIL developed the Emergency Response Plan - Sodium Cyanide (hereinafter referred to as the

Plan). The Plan is a document that covers all operations during the operations in the warehouse. A section

that describes the characteristics of sodium cyanide, emergency organization, communication protocol, and

emergency evaluation levels are included.

The scenarios are relate to releases of wooden boxes and action plan includes specific response to these

scenarios.

The Plan does not include instructions to evacuate communities. The possible scenarios have no

consequences beyond the limits of the MERCANTIL facilities. Furthermore, only handles MERCANTIL

sodium cyanide solid state (briquettes). In addition, the Plan includes specific instructions and detailed

response to the identified scenarios.

The Plan comprises a method for the treatment of poisoning of people spilled cyanide reaction portion

includes instructions for the use of cyanide antidotes and first aid procedures. The medical staff of the health

center is familiar with these procedures.

In The Plan actions in the case a spill occurs has specified actions to control of releases at their source.

MERCANTIL Plan will be review after an emergency. This would help prevent future releases.


INVOLVE SITE PERSONNEL AND STAKEHOLDERS IN THE PLANNING PROCESS.







17

The operation is in FULL COMPLIANCE whit Standard of Practice 5.2 requiring an operation involve site

personnel and stakeholders in the planning process.

The Chief Safety MERCANTIL developed the plan. The nearest residential area is located more than 1 km of

the facility. According to the emergency response procedure at worst an area of 400 m should be evacuate;

not covering the residential area.

However, MERCANTIL government informed the district about its operations and that require their support

MERCANTIL evacuate in an emergency.

MERCANTIL has contacted the local police, local firefighters, and ocal hospital, and informed them that are

consider as supporting facilities for emergency cyanide.

The Plan includes a communications protocol in writing stating the emergency communication should be with

all Stakeholders, including; Employees, Customers, Regulatory Agencies and other institutions.


DESIGNATE APPROPRIATE PERSONNEL AND COMMIT NECESSARY EQUIPMENT AND RESOURCES FOR EMERGENCY

RESPONSE.





The operation is in FULL COMPLIANCE whit Standard of Practice 5.3 requiring an operation designate

appropriate personnel and commit necessary equipment and resources for emergency response.

The Plan includes the name of the individual members of the emergency committee and outlines their roles

and responsibilities. In general, high - more current manager in place that authority is grant to provide all

necessary resources. The Plan also shows the contact number of the coordinators of alternative emergency

response.

The Plan determines that workers in the operation of cyanide will be part of the emergency team. Training in

emergency response is generally to all staff and this training is included in the annual training program the

same annual program.

The Plan shows the contact information of those responsible (Crisis Committee). This plan states that these

members have been give phones must respond at all times (24 hours).

In the Plan, MERCANTIL describes the roles and responsibilities of the emergency committee for each

emergency stage (before, during and after).

Plan includes a list of emergency response kit and personal protective equipment.

The site has implemented a checklist inspection prior to any operation with cyanide and equipment

availability was confirm during the audit.

The Plan also includes the role of outside responders.



18

The plan shows the contact details of all external entities involved. It further states that these entities are

inform on an annual basis on the contingency plan and operational risks.


DEVELOP PROCEDURES FOR INTERNAL AND EXTERNAL EMERGENCY NOTIFICATION AND REPORTING.





The operation is in FULL COMPLIANCE whit Standard of Practice 5.4 requiring an operation develop

procedures for internal and external emergency notification and reporting.

The plan includes a communication protocol that includes internal communication functions, as well as

notification to the authorities and external response personnel.

The Plan includes a directory of internal and external contacts. It also displays the contact information of the

entire team of internal and external response to emergencies; members of that team have telephones and

are available 24 hours a day that was check after calls to these numbers during the visit. Plan evacuation of

communities deemed necessary. Click for communication with Authorities and External Response

Personnel.

The warehouse is far more than 1 km radius communities. Communication with authorities and external

emergency responders was evident, which are included in the emergency response plan and those who are

informed in the event of an incident


INCORPORATE INTO RESPONSE PLANS AND REMEDIATION MEASURES MONITORING ELEMENTS THAT ACCOUNT FOR

THE ADDITIONAL HAZARDS OF USING CYANIDE TREATMENT CHEMICALS.





The operation is in FULL COMPLIANCE whit Standard of Practice 5.5 requiring an operation incorporate into

response plans and remediation measures monitoring elements that account for the additional hazards of

using cyanide treatment chemicals.

The plan describes the methodology to decontaminate, remediate soil or other contaminated materials and

dispose of all spill cleanup debris and bodies of water test for the presence of cyanide. the methodology

described below:

You must register your Personal Protective Elements (EPP's).



19

Isolate the affected area.

If cyanide is loose, shovel up and place in a plastic bag drums.

Had threat of rain, lime should be applied liberally over the spill of cyanide briquettes, in order to

maintain pH higher than 11.

If rain is imminent, cover the cyanide spill into a tent, plastic, canvas or waterproof material.

Dike with soil around the spill area to avoid rain water affects cyanide briquettes.

Wait until the rain the floor to dry, to continue the work of harvesting.

After the collection of cyanide, and based on a consensus decision with the authorities, can

decontaminate the exposed area with lime and then apply a 5% hypochlorite to destroy residual

cyanide. Rinse the area with water. An ideal way to apply hypochlorite is through a spray pump of

the type used in gardens. Let the hypochlorite is in contact with the affected area for 15 minutes at

least area.

The amount of lime and hypochlorite to be applied should be abundant (at least 2 times the

stoichiometric balance).

Allow the area to dry before lifting the barriers.

It is recalled that after each working day, personnel should remove disposable clothing and take

extra grooming habits before they leave the site.

If cyanide spill, no power or water body would be affected. The methodology presented is appropriate for the

organization

In the Plan prohibit the use of chemicals such as sodium hypochlorite, ferrous sulfate and hydrogen peroxide

to treat cyanide that has been released into surface water.

Based on the Risk Assessment Matrix, there is no potential to affect water bodies. None of specific scenarios

rather think that a spill would reach the floor or water. The monitoring is limited to the air and is carried out

with detector gas cyanide (HCN) portable.


PERIODICALLY EVALUATE RESPONSE PROCEDURES AND CAPABILITIES AND REVISE THEM AS NEEDED.





The operation is in FULL COMPLIANCE whit Standard of Practice 5.6 requiring an operation periodically

evaluate response procedures and capabilities and revise them as needed.

In the plan provides that the Chief Safety - MERCANTIL should review the Plan after each mock emergency

after emergency. According to the pages of signatures, the plan was under review at the time of the audit.

The site has an Annual Program of Emergency Drills including cyanide spill.



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